Ramesh Sanka v. ICAI and Anr - As Filed - 23012023

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• IN THE HIGH COURT OF DELHI AT NEW DELHI

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IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY WRIT JURISDICTION
W.P. (C) NO. ________ OF 2023
IN THE MATTER OF:

RAMESH SANKA ...PETITIONER
VERSUS
INSTITUTE OF CHARTERED ACCOUNTANTS

OF INDIA & ANR. …RESPONDENT(S)
INDEX
SR. NO. PARTICULARS PAGE NO.
1. Urgent application 1
2. Notice of motion 2
3. Court fee 3
4. Memo· of parties 4-5
5. Synopsis & list of dates 6-12
6. Writ petition under article 226 and 227 of the 13-41

Constitution of India seeking Writ of Mandamus or any
other appropriate Order directing Respondent No. 1 to
take action and investigate the complaint dated
28.02.2020 filed by Petitioner against Respondent No.
2 and issue primae facie opinion on gross professional
misconduct and non-compliance of provisions of the
Chartered Accountants Act, 1949 read with the
Chartered Accountants (Procedure Of Investigation Of
Professional And Other Misconduct And Conduct Of
Cases) Rules, 2007 along with Affidavit.
7. Annexure A-1: 42-81
Copy of Complaint dated 28.02.2020 (without
Annexures) filed by Petitioner to Respondent No. 1
against Respondent No. 2
8. Annexure A-2: 82-362
Copy of Written Statement filed by Respondent No. 2
to Respondent No. 1 on 31.07.2020
9. Annexure A-3: 363-437
Copy of Rejoinder filed by Petitioner on 07.09.2020 to
Respondent No. 1
10. Annexure A-4: 438-441
Copy of email dated 13.09.2022, 21.06.2022,
11.05.2022, 23.04.2022 sent by the Petitioner to the
representatives of Respondent No. 1
11. Annexure A-5: 442-449
Copy of articles dated 12.10.2021 and 17.11.2021 titled
‘Pandora Papers: Homebuyers, investors high and dry,
Ireo’s Goyal moved $77 million to offshore trust’ dated
12.10.2021 downloaded from the website of the Indian
Express
12. Annexure A-6: 450-460
Copy of the Order and Judgment dated 25.01.2019
passed by the Hon’ble Supreme Court of India in WP
(Crl.) No. 142 of 2018 titled as “Ramesh Sanka Vs
Union of India & Ors.”
13. Annexure A-7: 461-469
Copy of Order dated 18.03.2020 passed by the Hon’ble
High Court of Punjab & Haryana in case titled ‘Ireo
Private Limited Vs Union of India & Ors.’ bearing,
CWP No. 4513 of 2020
14. Annexure A-8: 470-473
Copy of Common Order dated 15.07.2019 passed by
the Hon’ble High Court in Writ Petitions bearing No.
W.P.(C) 7444/2019, W.P.(C) 7461/2019, W.P.(C)
7463/2019, W.P.(C) 7477/2019, W.P.(C) 7485/2019,
W.P.(C) 7488/2019, titled “Ramesh Sanka v. Institute
of Chartered Accountants of India and Anr.”
15. Annexure A-9: 474-528
Copy of prima facie Opinion dated 03.10.2019 passed
by Respondent No. 1 in File No. PR/275/18/DD-278/18
against CA Raj Kumar Agrawal
16. Annexure A-10: 529-581
by Respondent No. 1 in File No. PR/276A/18/DD-
310/18, against CA Nitin Gupta
17. Annexure A-11: 582-603
by Respondent No. 1 in File No. PR/274/18/DD-
277/2018, against CA Vijay Kumar Sharma
18. Annexure A-12: 604-623
by Respondent No. 1 in File No. PR/273/18/DD-
276/2018, against CA Priyanka Garg
19. Application under Section 151 Code of Civil 624-628
Procedure, 1908 seeking exemption from filing
certified copies and further seeking directions from
filing true typed/legible copies of dim documents,
underlined documents, documents not having requisite
font size and margins along with Affidavit
20. Vakalatnama 629
21. Proof Of Services 630
Filed By:
Zeba Khair/Shivambika Sinha/Nimita Kaul

(Advocates for the Petitioner)
27, Pocket-1, JasolaVihar
New Delhi-110025
9810602612
associate@legesworld.com
Place: New Delhi
Date of Filing: 17. January. 2023
1

W.P. (C) NO. ________/2023
IN THE MATTER OF:

VERSUS

URGENT APPLICATION
To,
The Registrar
High Court of Delhi
New Delhi-110012
Sir,
This Petition humbly submits that accompanying Petition is urgent
and the grounds of urgency are as prayed in the Petition and
Application for interim Relief. Petitioner therefore request for the
accompanying Petition to be listed on an urgent basis to ensure that
the prayers taken in the accompanying Petition are not rendered
infructuous and no prejudice or irreparable harm to the petition is
caused.
Filed By:

27, Pocket-1, JasolaVihar
Place: New Delhi New Delhi-110025
Date of Filing: 17. January. 2023 9810602612
2

W.P. (C) NO. ________/2023
IN THE MATTER OF:

VERSUS

NOTICE OF MOTION
Please take note that the above noted matter is likely to be listed on
__. 01.2023 before the Hon’ble High Court of Delhi. It is, therefore,
requested to enter appearance on the said date.
Filed By:

27, Pocket-1, Jasola Vihar
3

W.P. (C) NO. ________/2023
IN THE MATTER OF:

VERSUS

COURT FEES
Filed By:

New Delhi-110025
9810602612
Place: New Delhi
Date of Filing: 17. January. 2023
4

W.P. (C) NO. ________/2023
IN THE MATTER OF:

VERSUS

MEMO OF PARTIES
RAMESH SANKA
S/o Mr. Eswarudu Sanka
R/o 1611-B, Magnolias,
DLF-5, Gurgaon,
Haryana-122009 ….PETITIONER
VERSUS
INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA

Through President, ICAI
ICAI Bhawan, Indraprastha Marg Post Box No. 7100 7
New Delhi – 110002
E-mail: president@icai.in
Phone No. N.A …RESPONDENT NO.1
VISHESH JAIN
IInd Floor, Plot No-421, Sector-18, Phase-Iv, Udyog Vihar,
Gurugram, Haryana, Pin No-122016
5
E-mail:vinesh.jain@sndhawan.com
Phone No. 9811058612 …RESPONDENT NO.2
Filed By:

6

W.P. (C) NO. ________/2023
IN THE MATTER OF:

VERSUS

SYNOPIS AND LIST OF DATES
Petitioner is constrained to file the present Petition
against action/inaction by Respondent No. 1/ Institute of Chartered
Accountants of India, 1949 (ICAI ) for having neglected in
performing its duty and legal obligation and failing to issue prima
facie opinion as per provisions of Section 21 of ICAI Act upon
receiving Complaint dated 28.02.2020 filed by Petitioner, reporting
the issue of professional misconduct by Respondent No. 2/ Mr.
Vinesh Jain (Partner at S.N. Dhawan & Co.) in his capacity as
statutory Auditor for Ireo Pvt. Ltd. Respondent No. 2 is a Chartered
Accountant by profession, and has been actively involved in scam/
embezzlement of funds and tax evasion to the tune of INR 727
crores and more and hence is guilty of breach of his professional
oath. Respondent No. 2 acted hand in glove with Mr. Lalit Goyal
(Fund manager& VC & MD of Ireo Pvt. Ltd.) and other key

7
management personnel of Ireo Pvt. Ltd. in carrying out the massive
financial frauds and tax evasions and thereby has failed to discharge his
duties. It is submitted that Respondent No. 2 gave wrong disclosures,
non-disclosures and manipulated the books of accounts of Ireo Pvt. Ltd.
leading to concealment of vital information from the tax authorities,
investors and more essentially from the Government of India in order to
evade tax and siphon money illegally.
Petitioner had been appointed at the post of Chief Executive Officer
(CEO) at Ireo Pvt. Ltd. in June 2014 but after having discovered the
financial embezzlements going on in the Company, Petitioner shortly
resigned from his position with effect from 31.12.2016.
Petitioner is distressed by Respondent No.1’s inaction to investigate and
issue a prima facie opinion on the Complaint dated 28.02.2020 filed
against Respondent No. 2’s failure to discharge his duties as a statutory
auditor. Petitioner had placed sufficient material on record in the
Complaint dated 28.02.2020 filed against Respondent No. 2 to prove the
charges of professional misconduct. Moreover, approximately two years
have passed, and no action has been taken by Respondent No. 1 which
is a watchdog for regulating the profession of Chartered Accountants in
the country. A copy of said complaint dated 28.02.2020 was forwarded
to Respondent No.2 calling upon him to file his Written Statement. In
response thereto, the Respondent No.2 filed Written Statement dated

8
31.07.2020. Pursuant to filing of the Written Statements, Petitioner filed
his Rejoinder on 07.09.2020.
In view of the unexplained and inordinate delay in deciding the
Complaint by Respondent No.1, therefore, Petitioner was constrained to
send several representations/ notices dated 13.09.2022, 21.06.2022,
11.05.2022, 23.04.2022 to Respondent No 1. beseeching them to take
action against the above-mentioned illegal activities and requesting
them to expedite the matter and take disciplinary action as per law, but
to no avail.
It is submitted that the Petitioner has taken all steps and measures as
mandated under the Act/ rules & procedure, but Respondent No. 1 is not
carrying out its duties & functions enjoined upon it and it is not taking
any action against the Respondent No. 2. Petitioner had filed Complaint
to Respondent No.1 with a legitimate expectation that the same would
be adjudicated in accordance with law at the earliest. With the
expression, at the earliest, it is taken to be within a reasonable period of
time. In the present case, very serious allegations have been made
against the Respondent No. 2 but no concrete action/ prima facie opinion
has been publishes till date except for completing the technical
formalities. Therefore, Petitioner is constrained to approach this Hon’ble
Court by way of present Writ Petition.

9
LIST OF DATES
DATE PARTICULAR
June 2014 Petitioner was appointed at the post of Chief Executive
Officer (CEO) at Ireo Pvt. Ltd. (IPL)
21.12.2016 After having discovered the financial embezzlements
going on in IPL, Petitioner resigned from the position
with effect from 31.12.2016.
25.01.2019 Vide Order and Judgment dated 25.01.2019 passed in
WP (Crl.) No. 142 of 2018 titled as “Ramesh Sanka Vs
Union of India & Ors.”, the Hon’ble Supreme Court
of India was pleased to issue notice and direct Statutory
Authorities to file their respective status report in
relation to the inquiries conducted into the frauds
committed by Ireo Group of Companies, which is
being undertaken by them in their respective
jurisdiction.
October – GST department raided Ireo Group premises and
November detected huge tax evasions and collected Rs 29.40
2019 crores towards service tax.
15.07.2019 Petitioner had filed the Writ Petitions bearing No.
W.P.(C) 7444/2019, W.P.(C) 7461/2019, W.P.(C)

10
7463/2019, W.P.(C) 7477/2019, W.P.(C) 7485/2019,
W.P.(C) 7488/2019, titled “Ramesh Sanka v. Institute
of Chartered Accountants of India and Anr.” before
this Hon’ble Court on account of inaction on part of
Respondent no.1 in considering six separate
complaints of professional misconduct against six
Chartered Accountants. This Hon’ble Court passed a
Common Order dated 15.07.2019 whereby it was
pleased directions to the Director (Discipline), ICAI to
take a view as required under sub-section (2) of Section
21 of the Act as expeditiously as possible.
23.08.2019, Respondent No. 1 / ICAI vide orders held all five
03.10.2019, statutory auditors of the Ireo group of companies i.e.
11.10.2019 Mr. Raj Kumar Agarwal of S.R. Batliboi (EY), Mr.
and Anil Goel of Anil Amitta & Co, Mr. Vijay Kumar
16.10.2019 Sharma of Vijay Raj & Co, Priyanka Garg of Priyanka
Garg associates and Mr. Nitin Gupta, GM – Accounts
& Finance of Ireo Group, “GUILTY” for professional
and other misconduct falling within the meaning of
Clauses (4), (5), (7) and (8) of Part I of Second
Schedule, Clause (1) of Part II of the Second 11

11
Schedule and clause (2) of Part IV of the First Schedule
of the Chartered Accountants Act, 1949
28.02.2020 Petitioner filed a Complaint on 28.02.2020 to
Respondent No.1 reporting the issue of professional
misconduct of Respondent No. 2/ Mr. Vinesh Jain
(Partner at S.N. Dhawan & Co.) who was appointed as
statutory Auditor for Ireo Pvt. Ltd.
07.02.2020 The Principal Commissioner, CGST Commissionerate,
and Gurgaon, vide order dated 07.02.2020 provisionally
18.03.2020 attached the bank account of the Ireo Group of
companies under Section 83 of the Central Goods and
Services Tax Act, 2017. The Hon’ble High Court of
Punjab & Haryana vide judgment dated 18.03.2020
Haryana in case titled ‘Ireo Private Limited Vs Union
of India & Ors.’ bearing, CWP No. 4513 of 2020,
rejected the petition for relief filed by the Ireo Group
against Order dated 07.02.2020 passed by Principal
Commissioner, CGST Commissionerate, Gurgaon.
31.07.2020 Respondent No.2 filed written statement on 31.07.2020
to the Complaint dated 28.02.2020.

12
07.09.2020 Pursuant to filing of the Written Statements on
31.07.2020, Petitioner filed his Rejoinder on
07.09.2020.
12.10.2021 The Indian Express published an article on the Pandora
Papers investigation disclosing the involvement of
Respondent No. 3 in channeling funds illegally in
offshore accounts and being involved in money
laundering of about Rs. 2600 crores.
13.09.2022, Petitioner sent several representations/ notices to
21.06.2022, Respondent No 1. beseeching them to take action
11.05.2022, against the above-mentioned illegal activities and
23.04.2022 requesting them to expedite the matter and take
disciplinary action as per law, but to no directions were
passed.
In the present case, serious allegations have been made
against the Respondent No. 2 vide Complaint dated
28.02.2019, but no concrete action/issuance of prima
facie opinion has been undertaken till date by
Respondent No. 1. Therefore, the Petitioner is
constrained to approach this Hon’ble Court by way of
the present Writ Petition.

13

W.P. (C) NO. ________/2023
IN THE MATTER OF:

VERSUS

WRIT PETITION UNDER ARTICLE 226 AND 227 OF THE

CONSTITUTION OF INDIA SEEKING WRIT OF MANDAMUS
OR ANY OTHER APPROPRIATE ORDER DIRECTING
RESPONDENT NO. 1 TO TAKE ACTION AND INVESTIGATE
THE COMPLAINT DATED 28.02.2020 FILED BY PETITIONER
AGAINST RESPONDENT NO. 2 AND ISSUE PRIMAE FACIE
OPINION ON GROSS PROFESSIONAL MISCONDUCT AND
NON-COMPLIANCE OF PROVISIONS OF THE CHARTERED
ACCOUNTANTS ACT, 1949 READ WITH THE CHARTERED
ACCOUNTANTS (PROCEDURE OF INVESTIGATION OF
PROFESSIONAL AND OTHER MISCONDUCT AND CONDUCT
OF CASES) RULES, 2007
MOST RESPECTFULLY SHOWETH:
1. Petitioner is constrained to file the present Petition against
action/inaction by Respondent No. 1/ Institute of Chartered
Accountants of India, (ICAI ) for having neglected in
performing its duty and legal obligation and failing to issue a prima
14
facie opinion as per the provisions of Section 21 of ICAI Act, upon
receiving Complaint dated 28.02.2020 filed by Petitioner, reporting
violation of the Rules of Professional Conduct by Respondent No.
2/ Mr. Vinesh Jain (Partner at S.N. Dhawan & Co.)
2. Petitioner filed a Complaint dated 28.02.2020 before Respondent
No. 1 to bring forward irregularities and instances of professional
misconduct committed by Respondent No. 2 in his capacity as
statutory Auditor for Ireo Pvt. Ltd from 31.03.2018 to 31.03.2019
and renewed every year after that. Respondent No. 2, in connivance
with the key management personnel of Ireo Pvt. Ltd. failed to abide
by the statutory obligations cast upon him by ICAI Act and
Companies Act, hence is guilty of professional misconduct. Copy
of Complaint dated 28.02.2020 (without Annexures) filed by
Petitioner to Respondent No. 1 against Respondent No. 2 is
attached as Annexure A-1.
3. Ireo Pvt. Ltd. (“IPL”) is a flagship Company of Ireo Group.
Petitioner is highly distressed due to large scale frauds and defaults
perpetrated by IPL, Ireo Group, and its promoters, and key
management personnel. It is submitted that the modus operandi
adopted by IPL included routing of funds to India from various

15
entities based in tax havens like British Virgin Islands and
Mauritius; recording of fictitious expenses in the books of account;
writing off project in progress; interest-free loans and advances to
sister concerns and ’round-tripping’ of funds through shell
companies; and the creation of assets within and outside India.
Respondent No. 2 in connivance with the key management
personnel of IPL, facilitated the financial fraud, tax evasion and
embezzlement of fund.
4. In view of the above, Petitioner is distressed by Respondent No.1’s
inaction to investigate and issue a prima facie opinion on the
Complaint dated 28.02.2020 filed against Respondent No. 2’s
failure to discharge his duties as a statutory auditor. Moreover,
approximately two years have passed, and no action has been taken
by Respondent No. 1 who is a watchdog for regulating the
profession of Chartered Accountants in the country.
FACTUAL BACKGROUND
5. The present case pertains to public importance as the crimes
committed by Respondent No. 2 are not only against the present
Petitioner but also against society at large and different government
functionaries. Being a Chartered Accountant by profession,

16
Respondent No. 2 has been actively involved in
scam/embezzlement of funds and tax evasion to the tune of INR 727
crores and more and hence is guilty of breach of his professional
oath.
6. Petitioner is an honest, educated, and law-abiding citizen of India.
Petitioner has 33 years of professional experience and had been
appointed at the post of Chief Executive Officer (CEO) at IPL in
June 2014 but after having discovered the financial embezzlements
going on in the Company, Petitioner shortly resigned from his
position with effect from 31.12.2016. In fact, the Petitioner had
approached the Hon’ble Supreme Court as a whistle-blower in 2018
to bring forward the frauds committed upon both investors and
customers through the ‘round-tripping’ of funds through the various
companies of Ireo Group.
7. Respondent No. 1 is Institute of Chartered Accountants of India
(ICAI) and is incorporated under Section 3 of the Chartered
Accountants Act, 1949 (“ICAI Act”). The basic objective of the
ICAI Act is to regulate the profession of Chartered Accountants in
the country. ICAI being an autonomous statutory body has a well-
defined procedure for taking action in case of a Complaint of

17
Professional Misconduct. It is submitted that Respondent No. 1 is
incorporated under the ICAI Act enacted by the Parliament and is
an Instrumentality of the State and its actions have to be just,
reasonable and transparent. It is submitted that Respondent No. 1
falls within the definition of “State” as enshrined under Article 12
of Constitution of India and therefore, its actions are amenable to
the Writ Jurisdiction of this Hon’ble Court.
8. ICAI Act provides for the establishment of Council headed by the
Director (Discipline) along with Board of a Discipline and
Disciplinary Committee which exercises disciplinary proceedings
powers under Section 21 of the ICAI Act. In fact, the Authority
formulated under ICAI, the Disciplinary Committee, Board of
Discipline, Director (Discipline) are vested with the same powers
as a Civil Court under the Code of Civil Procedure, 1908.
9. Respondent No. 2 was appointed as statutory Auditor responsible
for auditing books of accounts of Ireo Group as per the Indian
Accounting standards. However, Respondent No. 2 acted hand in
glove with Mr. Lalit Goyal (Fund manager& VC & MD of IPL) in
carrying out massive financial frauds and tax evasions. It is
submitted that Respondent No. 2 gave wrong disclosures, non-

18
disclosures and manipulated the books of accounts of IPL leading
to concealment of vital information from the tax authorities,
investors and more essentially from the Government of India in
order to evade tax and siphon money illegally.
10. That adverting to the factual matrix necessitating the filing of the
present Petition before this Hon’ble Court is that the Petitioner
found out multiple acts of cheating, fraud, misappropriation of
public money and fabrication of records by the Fund Manager, Mr.
Lalit Goyal, Vice Chairman & Managing Director of the Ireo
Group Companies and his Associates. Subsequently, in a view to
expose the financial embezzlements committed in IPL company,
Petitioner spent around nine months collecting different documents
from various Statutory Authorities under Right to Information Act,
2005.
11. Thereafter, all the important/ relevant documents were handed over
by the Petitioner to the International Fund Houses who had invested
substantially in Ireo Fund – I and Ireo Fund – II. After due
verification and scrutiny of documents and confirmation of the
illegalities and acts of cheating, fraud and misappropriation of
Public Money, the two fund houses namely Axon Partners LLP and
19
The Children's Investment Fund Foundation, UK, these Fund
Houses made two different complaints with Economic Offences
Wing (EOW), Crime Branch, New Delhi against Mr. Lalit Goyal
and other Directors of Ireo Group Companies for cheating and
fraud to the tune of Rs. 10,963 Crores (Rupees Ten Thousand Nine
Hundred Sixty Three Crores Only).
12. After having discovered the aforementioned frauds committed in
IPL, the Petitioner, in accordance with the mentioned procedure in
the ICAI Act read with Chartered Accountants (Procedure Of
Investigation Of Professional And Other Misconduct And Conduct
Of Cases) Rules 2007, (“CA Rules”) filed a Complaint dated
28.02.2020, inter alia contending that Respondent No. 2 failed to
provide full and fair disclosures of IREO Pvt. Ltd’s financial
position and thereby contravened the provision contained in the
regulation and guidelines issued by Respondent No.1.
13. As per Section 21(2) of the ICAI Act read with Rule 9(1) of CA
Rules, it is provided that the Director (Discipline) of Respondent
No. 1 is under a mandatory obligation to provide a prima facie
Opinion, on the basis of which subsequent actions shall be taken.

20
The relevant section and rule has been reproduced thereafter as
under for the sake of reference:-
Section 21 (2) of ICAI Act:
On receipt of any information or complaint along with the prescribed
fee, the Director (Discipline) shall arrive at a prima facie opinion on
the occurrence of the alleged misconduct.
Rule 9(1) of CA Rules, 2007:
"The Director shall examine the complaint, written statement, if any,
rejoinder, if any, and other additional particulars or documents, if
any, and form his prima facie opinion as to whether the member or
the firm is guilty or not of any professional or other misconduct or
both under the First Schedule or the Second Schedule or both."
14. It is submitted that Respondent No. 2 deliberately engaged with the
senior management of Ireo Pvt. Ltd. and withheld key financial
position of Ireo Pvt. Ltd. resulting in siphoning of money and tax
evasions. Respondent No. 2 failed to report that directors of Ireo
Pvt. Ltd. conducted business by adopting various fraudulent
method and fabrication of financial statements. In fact, Respondent
No. 2 acted hand in glove with the defaulters which subsequently
resulted in large scale tax evasion and while collar crime. It is
submitted that Respondent No. 2 did not exercise due diligence and
21
was grossly negligent in conduct of his professional duties.
Petitioner had placed sufficient material on record in the Complaint
dated 28.02.2020 filed against Respondent No. 2 for him to face the
charges of professional misconduct.
15. Copy of the said complaint dated 28.02.2020 was forwarded to
Respondent No.2 calling upon him to file his Written Statement. In
response thereto, Respondent No.2 filed Written Statement on
31.07.2020. Pursuant to filing of the Written Statements, Petitioner
filed his Rejoinder on 07.09.2020. Copy of Written Statement filed
by Respondent No. 2 to Respondent No. 1 on 31.07.2020 is
attached as Annexure P- 2. Copy of Rejoinder filed by Petitioner
on 07.09.2020 to Respondent No. 1 is attached as Annexure P- 3.
16. The grievance of the Petitioner is that the Complaint filed by him
against Respondent No. 2 on 28.02.2020 is not being investigated
or examined except merely completing the pleadings in the matter.
That Respondent No. 1 is unnecessarily prolonging the enquiry of
Professional Misconduct committed by the Respondent No. 2
despite the passage of more than 34 months from the date when the
Complaint has filed with the Respondent No. 1.

22
17. In view of the unexplained and inordinate delay in deciding the
Complaint by Respondent No.1, the Petitioner was constrained to
write several representations/ notices dated 13.09.2022,
21.06.2022, 11.05.2022, 23.04.2022 to Respondent No 1
beseeching them to take action against the above-mentioned illegal
activities and requesting them to expedite the matter and take
disciplinary action as per law, but there was no action taken. Instead
of acting upon the complaints/notices of the Petitioner, Respondent
No. 1 paid no heeds to the emails sent by Petitioner and delayed the
publication of prima facie opinion on one pretext or the other. Copy
of email dated 13.09.2022, 21.06.2022, 11.05.2022, 23.04.2022
sent by the Petitioner to the representatives of Respondent No. 1 is
attached as Annexure P-4.
18. Moreover, as per the article titled ‘Pandora Papers: Homebuyers,
investors high and dry, Ireo’s Goyal moved $77 million to offshore
trust’ dated 12.10.2021 published in the Indian Express, it has been
reported that investigation related to Pandora papers has revealed
that Mr. Lalit Goyal(Vice Chairman & Managing Director of the
Ireo Group Companies), who is the mastermind of the above-
mentioned illegal actions, was engaged in ‘large-scale fraud by
‘illegally siphoning off’ at least $147 million of investor money,

23
although the actual sum could approach $200 million… Police in
New Delhi said they have received the complaint’. The aforesaid
amount of money siphoned off is the money of the homebuyers. It
is humbly submitted that in view of the above, Rs 396 crores, the
money involved in the Bhiwadi land transaction, is evidently a part
of illegal transfers, referred to above. It is therefore patently clear
that Mr. Lalit Goyal is engaging in money laundering through a
systematic channel by taking money outside India and has
accordingly been arrested as per the investigation being undertaken
by Enforcement Directorate (ED), which has the powers to
investigate and track such international money laundering cases.
Copy of articles dated 12.10.2021 and 17.11.2021 titled ‘Pandora
Papers: Homebuyers, investors high and dry, Ireo’s Goyal moved
$77 million to offshore trust’ dated 12.10.2021 downloaded from
the website of the Indian Express is attached as Annexure P-5.
19. It is submitted that the complex web of money laundering could
only be facilitated with the helped and facilitated with top
International Auditor Firms, such as Respondent No. 2’s firm along
with S.R. Batli Boi & Co. (Indian Division of Ernst & Young)
which were carrying out regular Audits of Ireo Group Companies
along with the other Statutory Auditors. With the assistance of the
24
several well-known Auditor firms and Respondent No. 2, IPL gave
effect to large-scale white-collar crimes and facilitated tax evasion
and flouting of accounting principles resulting in large scale
economic frauds.
20. Petitioner has filed multiple complaints to several statutory
authorities contending that IREO Group of Companies lead by it
Fund Manager were indulging in acts of cheating, fraud and
misappropriation of public money to the tune of Rs. 10,963 Crores
(Rupees Ten Thousand Nine Hundred Sixty-Three Crores Only)
and further there was evasion of statutory dues of the Govt.
amounting to Rs. 4,396 Crores (Rupees Four Thousand Three
Hundred Ninety-Six Crores Only). In these circumstances and
purely as a “Whistle Blower” with no personal interest whatsoever,
the Petitioner at his level filed a Writ Petition (Criminal) No. 142
of 2018 titled as “Ramesh Sanka Vs Union of India & Ors.” before
the Hon’ble Supreme Court of India for bringing out all the
complaints which he had made to the various Statutory Authorities
in the past and sought that in the overall facts and circumstances
and looking to the need of a Specialized Agency to investigate such
Inter-State Scam worth more than 10,963 Crores, the Investigation
of the entire matter be transferred to Central Bureau of

25
Investigation (CBI). The Hon’ble Supreme Court of India issued
notice to the following Authorities/ Respondents in the Writ
Petition filed by the Petitioner:
i. Central Board of Direct Taxes (CBDT).
ii. Commissioner of Police, Gurugram
iii. Commissioner of Police, Delhi
iv. Central Board of Excise & Customs (CBEC)
v. Serious Fraud Investigation Office (SFIO)
Hon’ble Supreme Court therefore dismissed the Writ Petition with
the following directions vide its Judgement dated 25.01.2019 as
under:-
“19. So far as the raising of other grievances as set out supra
by the writ petitioner against the other respondents are concerned,
suffice it to say, this court by order dated 11.07.2018 has issued
notice to the official respondents Nos. 7 to 11. These respondents
pursuant to the notice issued have filed their respective status
report in relation to the inquiries, which is being undertaken by
them in their respective jurisdiction. We have perused the same.
21. Needless to say depending upon the outcome of the inquiry once
it is completed by the respective official respondents in their
exclusive jurisdiction under various Acts, the appropriate action

26
as provided in law will follow against all those who are found
guilty.”
Copy of the Order and Judgment dated 25.01.2019 passed by the
Hon’ble Supreme Court of India in WP (Crl.) No. 142 of 2018 titled
as “Ramesh Sanka Vs Union of India & Ors.” is annexed herewith
as Annexure P-6.
22. It is further submitted that between October and November 2019,
the GST department conducted a raid at Ireo Group premises and
detected huge tax evasions and collected Rs 29.40 crores towards
service tax. The Principal Commissioner, CGST Commissionerate,
Gurgaon, vide order dated 07.02.2020 provisionally attached the
bank account of the Ireo Group of companies under Section 83 of
the Central Goods and Services Tax Act, 2017. The Hon’ble High
Court of Punjab & Haryana vide judgment dated 18.03.2020
Haryana in case titled ‘Ireo Private Limited Vs Union of India &
Ors.’ bearing, CWP No. 4513 of 2020, rejected the petition for
relief filed by the Ireo Group. Copy of Order dated 18.03.2020
passed by the Hon’ble High Court of Punjab & Haryana in case
titled ‘Ireo Private Limited Vs Union of India & Ors.’ bearing,
CWP No. 4513 of 2020 is annexed herewith and marked as
Annexure P-7.
27
23. Petitioner had earlier filed the following Writ Petitions bearing No.
W.P.(C) 7444/2019, W.P.(C) 7461/2019, W.P.(C) 7463/2019,
W.P.(C) 7477/2019, W.P.(C) 7485/2019, W.P.(C) 7488/2019,
titled “Ramesh Sanka v. Institute of Chartered Accountants of India
and Anr.” before this Hon’ble Court on account of inaction on part
of Respondent no.1 in considering six separate complaints of
professional misconduct against six Chartered Accountants. Vide
Common Order dated 15.07.2019, this Hon’ble Court was pleased
to pass directions to the Director (Discipline), ICAI to take a view
as required under sub-section (2) of Section 21 of the Act as
expeditiously as possible. Copy of Common Order dated
15.07.2019 passed by the Hon’ble High Court in Writ Petitions
bearing No. W.P.(C) 7444/2019, W.P.(C) 7461/2019, W.P.(C)
7463/2019, W.P.(C) 7477/2019, W.P.(C) 7485/2019, W.P.(C)
7488/2019, titled “Ramesh Sanka v. Institute of Chartered
Accountants of India and Anr.” is attached as Annexure P-8.
24. It is pertinent to note that on the basis of the aforementioned Order
dated 15.07.2019 passed by this Hon’ble Court, the Director
(Discipline) issued a prima facie Opinion dated 23.08.2019,
03.10.2019, 11.10.2019 and 16.10.2019 passed in File No.

28
PR/273/18/DD-276/18, File No. PR/323/18/DD-340/18, File No.
PR/276A/18/DD-310/18, File No. PR/275/18/DD-278/18 and File
No. PR/274/18/DD-277/18, respectively. Respondent No. 1 has
held all five statutory auditors of the Ireo group of companies i.e.
Mr. Raj Kumar Agarwal of S.R. Batliboi (EY), Mr. Anil Goel of
Anil Amitta & Co, Mr. Vijay Kumar Sharma of Vijay Raj & Co,
Priyanka Garg of Priyanka Garg associates and Mr. Nitin Gupta,
GM – Accounts & Finance of Ireo Group, “GUILTY” for
professional and other misconduct falling within the meaning of
Clauses (4), (5), (7) and (8) of Part I of Second Schedule, Clause
(1) of Part II of the Second Schedule and clause (2) of Part IV of
the First Schedule of the Chartered Accountants Act, 1949.
Respondent No. 1 found that these statutory auditors in connivance
with Mr. Lalit Goyal and other persons in management of the Ireo
Companies have helped the Ireo Group of Companies in falsifying
their accounts and withholding information pertaining to related
party transactions etc.
Copy of prima facie Opinion dated 03.10.2019 passed by
Respondent No. 1 in File No. PR/275/18/DD-278/18 against CA
Raj Kumar Agrawal is attached as Annexure P-9. Copy of prima
facie Opinion dated 11.10.2019 passed by Respondent No. 1 in File
No. PR/276A/18/DD-310/18, against CA Nitin Gupta is attached

29
as Annexure P-10. Copy of prima facie Opinion dated 23.08.2019
passed by Respondent No. 1 in File No. PR/274/18/DD-277/2018,
against CA Vijay Kumar Sharma is attached as Annexure P-11.
Copy of prima facie Opinion dated 23.08.2019 passed by
Respondent No. 1 in File No. PR/273/18/DD-276/2018, against CA
Priyanka Garg is attached as Annexure P-12.
25. At the outset, under the disciplinary regime, contemplated in the
Chartered Accountants Act, 1949 and the Rules and Regulations
framed thereunder, there are various tiers through which a
complaint filed against any member of the ICAI is processed. At
the initial stage, a complaint filed against a member, is referred to
the Director (Discipline), to ascertain as to whether a prima facie
case is made out, based on the complaint and material filed
therewith.
26. It is submitted that in fulfilment of its legal and statutory duty
imposed by Section 21 of the Chartered Accountants Act 1949,
Respondent No. 1 was under a mandatory obligation to establish a
Disciplinary Directorate headed by an officer of the Institute
designated as Director (Discipline) and such other employees for
making investigations in respect of any information or complaint
received by it. Further, on receipt of any information or complaint

30
along with the prescribed fee, the Director (Discipline) was under
a mandate to arrive at a prima facie opinion on the occurrence of
the alleged misconduct.
27. In view of the unexplained and inordinate delay in deciding the
Complaint by Respondent No.1, therefore, the Petitioner wrote
several representations/ notices dated 13.09.2022, 21.06.2022,
11.05.2022, 23.04.2022 to Respondent No 1. beseeching them to
take action against the above-mentioned illegal activities and
requesting them to expedite the matter and take disciplinary action
as per law, but to no avail. Instead of acting upon the
complaints/notices of the Petitioner, the Respondent No. 1 paid no
heeds to the emails sent by Petitioner and delayed the publication
of prima facie opinion on one pretext or the other.
28. The Petitioner had filed Complaint to the Respondent No.1 with a
legitimate expectation that the same would be adjudicated in
accordance with law at the earliest. With the expression, at the
earliest, it is taken to be within a reasonable period of time. In the
present case, very serious allegations have been made against the
Respondent No. 2 but no concrete action has been taken till date
except for completing the technical formalities. This delay in not
deciding the matter is causing substantial damage not only to the

31
petitioner but also to general public who believe that the
Respondent No. 1 would take action and the guilty would be
punished in accordance with law.
29. It is submitted that Chartered Accountants, governed under the Act
are accountable for their professional conduct and thereby do not
enjoy any immunity if they are found to be indulging in the acts of
Professional Misconduct. It is submitted that the acts of
Professional Misconduct in the present case have not only caused
loss to the general Public but also loss to the Government in as
much as the statutory dues of the Government have been evaded
and the said Respondent No. 2 has acted in connivance with the
Wrongdoers in such evasion. Lastly, the acts of Professional
Misconduct of the Respondent No. 2 also have criminal overtones
and a separate enquiry ought to be initiated into that aspect as well.
Respondent No. 1 is a competent Authority and cannot only take
action as per the ICAI Act, against any Chartered Accountant for
Professional Misconduct but it can also recommend and make
appropriate Complaint to the Police, if the actions of Professional
Misconduct have in any way breached the Provisions of Indian
Penal Code.
32
30. It is submitted that Petitioner has taken all steps and measures as
mandated under the Act/ rules & procedure but the Respondent No.
1 is not carrying out its duties & functions enjoined upon it and it
is not taking any action against the Respondent No. 2. Therefore,
the Petitioner is constrained to approach this Hon’ble Court by way
of the present Writ Petition.
GROUNDS
Petitioner is aggrieved by the actions/inaction on part of
Respondent No. 1, and is approaching this Hon’ble Court on the
following grounds:
A. Because Respondent No. 1 is duty bound to take action and
arrive at a prima facie opinion on the basis of the Complaint
filed by Petitioner No. 1 and investigate the charges of
professional misconduct levied on Respondent No. 2 under the
Chartered Accountants Act, 1949.
B. Because, Respondent No. 1 even after receipt of the complaint
has taken no action against the Respondent No.2 who have till
33
date been diverting the funds for their personal gain and
enrichment. Respondent No. 1 has despite lapse of substantial
amount of time has duly failed to comply with the duty vested
with it and has acted against the objectives of the Chartered
Accountants Act, 1949.
C. Because, Respondent No. 2 despite lapse of substantial amount
of time has failed to comply with the procedure of arriving at
prima facie opinion and thus acted against the objectives of the
Chartered Accountants Act, 1949 read with The Chartered
Accountants (Procedure Of Investigation Of Professional And
Other Misconduct And Conduct Of Cases) Rules, 2007.
D. Because, Director (Discipline) of Respondent No. 1 on perusal
of all the documents, i.e., Complaint, Written statement,
rejoinder was under a statutory obligation to form a prima facie
opinion on the charges of professional misconduct on the part
of Respondent No. 2.
34
E. Because, Respondent No. 1 despite receiving the complaint on
28.02.2020 which completely highlights the fraud committed
by the Respondent No.2 in the light of the facts that the money
has been siphoned off from one account to another which were
in complete disregard to the objectives of ICAI Act and no
proper due diligence being conducted by the Respondent No. 2
while auditing the accounts of Ireo Pvt. Ltd. thereby causing
huge loss to the public at large.
F. Because, conduct of Respondent No. 2 in associating with the
methods of tax evasion rather than denouncing them, to say the
least, is a gross misconduct on the part of a member of a noble
profession which is worse than solitary lapses of the tax payers
and hence requires the utmost attention of Respondent No. 1.
G. Because it is completely within the domain and powers of the
Respondent No. 1 to investigate the charges levied against
Respondent No. 2 under the Chartered Accountants Act, 1949
whereby the Respondent No. 1 is solely empowered and
equipped to publish prima facie opinion and bring justice.

35
H. Because, Petitioner had filed Complaint to the Respondent
No.1 and had a legitimate expectation that the same would be
adjudicated in accordance with law at the earliest. With the
expression, at the earliest, it is taken to be within a reasonable
period of time. In the present case, very serious allegations have
been made against the Respondent No. 2 but no concrete action
has been taken till date except for completing the technical
formalities.
I. Because dereliction of the duties and powers vested with the
Respondent No. 1 for the purpose of investigating the offences
under Chartered Accountants Act, 1949 is causing loss to the
public at large with each day passing by and it is incumbent
duty of the Respondent No. 1 to investigate the claims raised in
the complaint.
J. Because due to the failure on the part of the Respondent No. 1
for not exercising powers vested with it to investigate the
offences under the Chartered Accountants Act, 1949 is against
the well settled principles of law and failure to immediately act
and taking timely action by the Respondent No. 1 shall cause

36
and result in the travesty of justice as even after repeated
remainders by Petitioner, Respondent No. 1 has failed to abide
by its duty.
K. Because, Respondent No.1 on the other hand is maintaining a
studied silence and not taking any action whatsoever. It is
submitted that the Respondent No. 1 is an Authority which is
governed under the Chartered Accountants Act, 1949 and falls
under the definition of “State” as enshrined in the Constitution
of India and is thus amenable to Writ Jurisdiction of this
Hon’ble Court.
L. Because, Chartered Accountant as a member of the institute,
has a role to play in the society and is required to observe high
standards of integrity and professional ethics and is expected to
discharge his professional obligation to discourage tax evasion
and not to indulge in methods of tax evasion which have the
effects of looting the government and the general public at
large.
M. Because, it is the statutory obligation of Respondent No. 1 in
dealing with the matter of professional propriety and cannot

37
ignore the fact that the profession of chartered accountant is an
honourable profession and it occupies a place of pride in the
liberal professions of the country. Any conduct which makes a
person unworthy to belong to the noble fraternity of chartered
accountant or makes an advocate unfit to be entrusted with the
responsible task of looking after the financial interests of the
general people must be regarded as conduct involving grave
professional misconduct.
31. The Petitioner crave leave of this Hon’ble Court to plead any
additional grounds and the above stated grounds are not the only
grounds in light of the facts and circumstances of the present
petition.
32. It is submitted that the Hon’ble Court has power and jurisdiction to
entertain and adjudicate the present petition and pass appropriate
writ/directions in the given facts and circumstances of the present
case. The Petitioner having no other efficacious remedy has
approached this Hon'ble Court in order to secure the ends of justice

38
and to direct Respondent No. I to furnish the prima facie opinion at
the earliest instance and secure the ends of justice.
33. Petitioner has not filed any other similar Writ Petition earlier for
the relief claimed herein either in this Hon' ble Court or in any other
High Court or before the Hon'ble Supreme Court of India.
34. The annexures filed along with this Writ Petition are true copies of
their respective originals.
35. The present Petition has been made bona fide and in the interest of
justice.
PRAYER
In view of aforesaid what has been stated hereinabove, it is therefore,
it is most respectfully prayed that this Hon'ble Court may be pleased
to:
a. Issue Writ of Mandamus or any other Writ or Direction
thereby directing Respondent No. 1 to take appropriate action
and investigate the complaint dated 28.02.2020 filed by
Petitioner against the Respondent No. 2 in a time bound
_ manner, issue prima facie opinion on gross professional
misconduct by Respondent No. 2 in non-compaliance of CA
Act, 1949 and rules thereunder, and file its Action taken
Report before this Hon'ble Court.

39
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Telangana 03
ANNEXURE A-1 42
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ANNEXURE A-2 82
nrE lI'~s r1ru rE oF C11ARTERED AccocNTANTS or I.'\DlA
CONFIDENTIAL
SPEED POST A,Q,
·,ub: 1-ILl;tl.9. rr1,1tter.Q.L~on1ni.!:~i1Jt made by YQ1L,51qainst CA. Vine.sh J.~.!!L91..tll5., . . S

!S Q!:H:nYmL!;it, ~.Q.1,,J,,e.,_s;hartered Accountants, Delhi, under Section 21 of
ttt~ ..~rrnrtercd Accountants Act, 1949,
11 1,Jon 1<:111,:c1 1N1th tne prov1s1ons cf Ruic 8(4) ot tile Chartered Accountants ( Proccdu 1 e ui
>;rq<1Uons of F1rofcss1or:a! ti:Kl Other Misconduct and Conduct of Cases) Ruic'.<;, :JOO/ fherc1!Y1rtcr,
·'. ·n·•J u1e ''::;;nd we are Si.;1 hercvvitr·1 G>py or the written ,;t;1tcrncnl :1atcc1 3l't
•,.:;y. ?020 1brn;ttr:,J l>y CA. Vinesh Jain of M/s. S N Ohawan & Co. LLP, Chartered
,u::ountants, Dc-lhi. A copy of UK: sa1cl ku!es :s enc!cse<1 ncrcwitn vour
(Ms. SRIMATHI P',:ZAl<ASH)

EXECUTIVE OFFICER
DISCIPLINARY DIRECTORATE:
· :,ddii 1011, 0
'f<)li 1re aiso n>que1;ted tO submit a scanned topy ot yo1i1 1b1y signed lhiJorncler an:i a1st> SHH: t \,_. ,. , .
~'J"'ld HH <1ld1 CD .Jh.L·19 ..t.r1tn 1-r11..:~ hiH'O "·opy.
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To 31 July, 2020
Ms Srimathi Prakash
Executive Officer
Disciplinary Directorate
Institute of Chartered Accountants of India
New Deihl
Dear Ms Srimathi Prakash,
Sub: In the matter of complaint made by Shri Ramesh Sanka {complainant) against the under-
signed (respondent) under Section 21 of the Chartered Accountants Act, 1949
Case No: PR - 81/2020-DD/108/2020

Ref: i} Your letter dated 13,h June 2020
ii) Our request for additional time for filing the submission dated 2.6 June, 2020
iii} Your E-mail dated 26 June, 2020 Confirming extension ·.1pto 25 July, 2020.
iv) Our E-mail dated 21 July, 2020 requesting further extension of time for filing our
submission.
v} Your E-mail dated 21 July 2020 Confirming of time for additional 10 days.
The undersigned is in receipt of Form I dated 18 th May 2020 filed by the complainant togr:thcr
with various other attachments,
Our response to the same is contained in the following sections:
A} Preliminary Submissions
B) Response to the charges with prejudice to contents of preceding par,1graphs
C) Use of the word ''Gross Negligence"
D) Condusions and Prayer
The undersigned is engagement and signing partner for the statutory audit of IREO Private Lim-
ited (IPL) for the years 2017-18 and 2018-19, and for various other SPV entities (jointly referred
as IREO). The firm of the respondent M/s. S, N. Dhawan & Co. LlP, has audited the books of
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account ot IPL and various other entities for the two years specified above. The respondent was
not the engagement partner in respect of all entities. Complete details in this respect are avail-
able in Para 3.18 below.
It is further brought to your notice that the responses in Part Bare without prejudice to the con
tents of Part A, and the undersigned reserves the right to submit his written statement in accord·
ance with the applicable Rules governing the disciplinary mechanism of !CAI, if and when the
charges of professional misconduct are made known to him as dealt with in Paras 2. and 3 below.
A. Preliminary Submissions
1. About the complainant
1.1 At the outset, we would like to give brief background on Mr. Ramesh Sanka which can demon:
strate his character, and his activity in the recent years as a habitual litigant, more so his pro-
tracted habit of misusing the disciplinary mechanism of !CAL
1.2 The Complainant, Mr. Ramesh Sanka hc1s been closely associated with lreo Pvt. ltd. with his
grievances against the company, and has preferred to file complaints with most of the Govern
ment authorities in the country . and we would like to give brief background about him. He was
the CEO of lreo Private Limited from July 2014 to December 2016. I! is extremely ironical that
whereas he would have been the top decision maker during that period, he is including transac
tions relating to the same period in his allegations. Even for transaction the following period, his
complaint is a perfect example of vengeance against an entity, and the professionals engaged
with such entity, with which he is embroiled in various litigation. Such practices of the members
or former members ot the management ot business entities net}d to be nipped in the bud with
an iron hand. Not only are such practices unethical, they can result in creation of circumstances
where working between the auditors and the management c;;,n become impossible. Such com
plaints are a perfect example of misuse and abuse of the disciplinary mechanism of !CAI.
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1.3 The Complainant also preferred a writ petition before the Hon'ble Supreme Court of India
seeking inquiries and investigations from all authorities including the SFIO, Commissioner of Po
lice, Delhi, Commissioner of Police, Gurugram, Central Board of Direct Taxes, GST, but the writ
petition was dismissed ultimately after issuing Notices, We have been provided these details by
the management of IPL. The Complainant instituted multiple procEiedings against IREO, its Man
agement and anyone else the complainant had perceived to have any connection with IREO.
1.4 The Complainant due to the grievances against Management of lreo has filed this complaint
as well. In fact, without actually disclosing to the !CAI, the complainant has added one more corn-
plaint under Section 21 of the Chartered J:l.ccountants Act. We have been given to understand
that he has already filed 5 complaints against other chartered accountants regarding their en
gagements with lreo Private Limited or companies that were involved in the business as SPVs.
Law cannot permit such abuse of the disciplinary mechanism that has been instituted for better
and appropriate purposes.
1.5 As per the information available on website, the Complainant has a nefarious track record of
misconducts to his narne during his pn:vious employments. One of the misconduct proceedings
was initiated by SEB! and even an FlR was lodged at Parliament Police Station against the accused.
The misconduct of the Complainant in the said IPO was adjudicated by SEBI along with other
severc1I dllegations with regard to collusion, mis-representation anc non-compliance by the Com-
plainant. He was given the exemplary punishment by SEBL In this regard tt1e Complainant was
restrained from accessing the securities market and prohibited from buying, selling or dealing
with securities, directly or indirectly for a period of 3 (three) years by the Order of SF.Bl (see
Pages 87 to 89}. This demonstrates the ma!afide intentions of the Complainant and any alle
gation of professional misconduct made by such a person needs to be reviewed from the angle
of an ulterior motive that he would be having. The Director Discipline must review this complaint
considering that it merely contains vindictive and empty words of a man who has not come be-
fore ICAl with clean hands.
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1.6 In one criminal complaint, ld. Judicial Magistrate, pt Class, Gurgaon rejected the complaint
of the complainant Mr. Ramesh Sanka with the following order:
" ..... Filing of this criminal compfaint during pendency of court proceedings reflects that per-
haps complainant wants to take undue benefit of the fact that accused persons (petitioners
and plaintiffs in petition pending before Hon'ble Supreme Court of India and District Court,
Gurugram) are facing trial in a criminal case. That should not be aHowed by the court. No
doubt, at the stage of summoning, there is requirement of prima facie· case but criminal pro-
ceedings should not be allowed to be used to settle score over each other. A criminal pro·
ceeding ought not to be permitted to degenerate into a weapon of harassment and perse
cution. Keeping in view the entirety of the facts and circumstances of the case. it appears
that parties are having civil disputes pending before the court and when dispute is of civil
nature, giving the proceedings a criminal colour is abuse of the process of law ..... "
1. 7 The aforesaid clarifies that the complainant is misusing the whoh! machinery with maiafide
intentions for harassment and persecution to serve his personal goals. We have come to know
that The Children's Investment Fund Foundation (UK}, Axon Partners, LP and Axon International .
LP, have written letters dated 12.08.2019 through Trifegal, a Legal Firm acting on behalf of the
lnvestors, and letter dated 09.10.2019 directly to !CAI, which are enclosed included on Pages
90 to 95. They have requested the Institute to withdraw the complaints which were made on
behalf of them against some other members of !CAL They have updated the Institute about the
background, intentions and motives of the complainant for the complaint made against some
other members of !CAL They have also informed that Mr. Sanka f.:Iiled to disclose certain key
and material facts to them, which had they known about the Complaint, they would not have
initiated those complaints with the Institute of Chartered Accountants of India. Further they
have been provided with other information, which has caused them to query the accuracy of
the information and the good faith of the assistance and services provided to them by the com-
plainant. According to Investors, the complainant's claims are without merit and shoutd be re
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jected in their entirety. This shows that the intent and purpose of the complaint is purely mali-
cious. As per Investors letter the complainant was paid a significant amount of money for his
services, and now he is demanding large amounts in excess of his contractual remuneration for
ceasing his campaign against the lreo Group. This is the root cause of the various complaints
being fifed by him, simply to bring pressure on the management of lREO; but in the process, the
chartered accountants are suffering the rigours of the disciplinary mechanism. The Complainant
has not filed any complaint in public interest, rather he has filed the complaint for his self-mo
tives and to fulfill his greed. This forum cannot be allowed to serve such motives of individuals
who are indulging in pure harassment of professionals. The complainant however has continued
wlth the spree of filing complaints against the members of !CAI, and the complaint against the
undersigned appears to be his latest initiative. This inquiry ought not to been initiated, and must
be closed forthwith.
1.8 On 30.03.2020 the Company lreo Pvt Ltd. has filed a complaint against the complainant for
offences punishable under Section 381 and 409 of Indian Penal Code with Police, Gurugram in
regard to the theft of the movable property i.e. documents, data, information, records of his
employer, !reo Pvt. ltd. and caused wrongful gains to himself and wrongful loss to the cornpany.
The accused Ramesh Sanka has, as stated in that compliant, committed the offence of cheat-
ing/breach of trust and defamation. Copy of the same is attached herewith (Pages 96 to 105 ).
1.9 It is evident that the complainant is abusing the right to use the platform of the disciplinary
mechanism of ICC\! by resorting to harass multiple members of !CAI, to eHcit information that may
be uscfu! for him in his othor litigations with lREO and to bring pressure upon the company by
causing damage to the professional accountants engaged with IPL and other companies. Thi',
should not be permitted under any circumstances. Complaints from ar, individual of this nature
and containing assertions that as unsubstantiated and purely based on his biases and prejudices,
as dealt with in the subsequent part of this submission, should not ever result in the initiation of
an inquiry for professional misconduct.
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2. Process of law not followed:
2.1 The inquiry for professional misconduct could not have been initiated under the disciplinary
mechanism of KAI for further reasons as discussed below:
• That an enquiry for Professional and Other Misconduct against a member of ICAl is re-
quired to be conducted in accordance with Section 21 of the Chartered Accountants Act
(referred as the Act) and the procedures prescribed in the Chdrteced Accountants (Pro-
cedure of Investigations of professional and other Misconduct and Conduct of Cases)
Rules, 2007 (referred as the Rules} .
.. That the Rufes required a complaint to be filed in Form-I mandatorily. The use of the
word "shall" in section 21{4) of the Act makes it obligatory that strict adherence to the
prescribed procedures is ensured .
.. That Form-! mandatorily requires the complainant to specify the particulars of the alle-
gations together with the corresponding C!ause/Part/Re!evant Schedules to the Char
tered Accountants Act under which the allegations are made.
• That the Director Discipline is required to scrutinize the complaint filed, and the Rules
specifically state the procedure to be followed for removal of any defects, failing which
the matter would be required to be closed.
• That any complaint against a member of !CAI is governed by the provisions of Section 21
of the Chartered Accountants Act (hereinafter referred to as the Act).
• That the procedure to be followed in the investigations againsl any Chartered Account-
ant for professional misconduct are contained in the Chartered Accountants (Procedure
of Investigations of Professional and Other Misconduct ard Conduct of Cases) Rules,

2007 (hereinafter referred to as the Rules).
2.2 It is further stated that:
• Clause 3(1) of the Rules requires the complaint to be filed in Forni-I
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• The mandatory requirements contained in Form-I Point No: 5 obligate the complainant
to state the Clauses, Parts and the relevant Schedules under which the allegations would
fall.
• Clause 5(2) of the Rules requires the Director Discipline to scrutinize the complaint.
• Clause 5(5) of the Rules provides the Director Discipline the opportunity to have any de-
fects in the complaint rectified by the complainant.
• Clause 5{6} of the Rules clearly states that if the defects are not removed, the Director
Discipline is obligated to form an opinion that there is no case against the respondent.
• Clause 8{1) of the Rules requires the Director Discipline to forward the complaint to the
respondent.
• Clause 8(3) of the Rules requires the respondent to submit a written staternent in his
defence. However, the written statement of the respondent can be submitted only after
the requirements for a valid compliant are complied with.
Clause 9(2) of the Rules requires the Director Discipline to form a Prima Facie Opinion if
at all the respondent is guilty for professional misconduct under the First Schedule or the
Second Schedule; the opinion of the Director Discipline accordingly has to be referred to
the Board of Discipline or the Disciplinary Committee depending upon the allegations
falling under any of the Clauses of the First Schedule, or the Second Schedule or both
schedules.
2.3 In any case, since the complainant has not specified the Clauses/Parts/Schedules in Form I,
the Director Discipline will not be able to proceed in this matter, and the purpose of investiga-
tions wilf not be achieved. The respondent also cannot file his written statement as he docs not
know the dauses/parts of the two Schedules to the Act under which he is charged for protes-
sional misconduct.
2.4 Since the complaint has not indicated (as per the mandatory requirements of Form ! in which
the complaint is made) the Clauses, Parts and the Schedule under which allegations have been
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made, and further since the Director Discipline has not opted to get the rectification done in the
complaint, there is no stage contemplated in the Rules governing the fnvestigations against mem-
bers of !CAI under the Act to file a written statement in such circumstances.
2.5 If ever a respondent would be forced to file a statement in his defence without knowing the
Clauses under which he is charged, he would basically be expected to first assign the Clauses
under which allegations are made against himself, and then present his defence. He would thus
be acting as the compla nant and the respondent. This is no case of self admission, and such
directions (as contained in your letter) to file a written statement without identification of the
Clauses/parts/Schedules of the A.ct under which allegations are made are ill-founded, ill-con-
ceived and not within the ambit of the legal procedures.
2.6 That any r2spondent has a legal right to submit his legal statement to defend himself once
the charges is made knowT1 to him. In the absence of the charges made known to the respondent,
the question cf his providing a written statement in his defence does not arise.
2. 7 That the Dfector Discipline {DD} is not authorised to improve or enhance the complaint as he
is in a position of an adjudicating officer. The DD cannot assign any charges, he is not empowered
to do so.
2.8 Three issues emanate from the Form I dated 18th March 2020 submitted by the complainant:
i) Against Serial No: 5 wherein the complainant is required to provide particulars of

the allegations with corresponding Clauses/Parts of the relevant ~chedutes tu l11e
Chartered Accountants Act under which charges of professional misconduct are
made, he has merely stated five serial numbers with the following words "As per
statement attached". There is no rc!evance to the five serial numbers; and further
through the entire Form I and all attachments to the said Form, there is no refer
ence to any Clause/Part of the relevant Schedules to the Chartered Accountants

Act under which the alleged acts of commission or omission or both would fall.
The respondent is thus clueless about the charges of professiona I misconduct lev
iecl against him.
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ii) Under Serial No: 6 of Form l which requires the complainant to state the particu·
!ars of evidence in support of the allegations, the complainant has merely stated
as follows: "As Attached". There is no identification of any document earmarked
as evidence. However, one thing is established for sure: That the complainant can
introduce no further docurnents as evidence in support of the allegations.
iii) Under Serial No: 7, where the complainant is required to provide names of persons
who have knowledge of the case: "GST Department and !CAI". One fails to under•
stand what the complainant wishes to accomplish by including GST Department
and ICAI while referring to the persons who have knowledge of the case. It may
specifically be noted that the complainant is a habitual litigant and has experience
of filing complaints under the mechanism of !CAI as discussed in Para 1.3. Further,
law requires that the process prescribed by the statute shall be specifically fol-
lowed in matters of this nature.
2.9 Your specific attention is drawn to the judicial pronouncements in Surath Chandra
Chakrabortti vs State of West Bengal (1971 AIR 752):
"The grounds on which it is proposed to take action have to be reduc0d to the form of a definite
charge or charges which have to be communicated to the person charged together with a
statement of the allegations on which each charge is based and any other circumstance which it
is proposed to be taken into consideration in passing orders has also to be stated. This rule
embodies a principle which is one of the basic contents of a reasonable or adequate opportunity
for defending oneself. If a person is not told clearly and definitely what the allegations are on
which the charges preferred against him are founded he cannot possibly, by projecting his ow11
imagination, discover al! the facts and circumstances that may be in the contemplation of the
authorities to be established against him."
Further clarified that the Supreme Court of India in the order of M.V. Bijlani vs Union Of India &
Ors {Appeal (civil} 8267 of 2004) stated:
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"He cannot enquire into the allegations with which the delinquent officer had not been charged
with."
2.10 In view of the 3 issues referred above, the respondent fails to understand as to why and how
inquiry has moved to a stage wherein the undersigned has been instructed to file a written state·
ment without appropriate rectification permissible under the Rules. The Disciplinary Directorate
could not have taken cognizance of the complaint filed and proceeded with the enquiry. No in•
quiry can be initiated when charges are not specified and the evidence in support of the allega·
tions ls not brought forward by the complainant. This inquiry must be closed forthwith.
3. Non maintainable assertions of the complainant
3.1 Following the Form I the very next page starts with the heading: "Comp!amt for fraudulent
and criminal conspiracy by Shri Vinesh Jain (Membership No: 087701) in respect of his gross neg
ligence and his connivance with the management in falsification of accounts of IREO Private Lim·
ited and its group companies."
3.2 The Supreme Court of India in S N Palanitkar and Ors Vs State of Bihar and Ors (jAIR CRI SC
953 of 2001), held that it is necessary to show that the accused had fraudulent or dishonest in
tention at the time ot making the promise. It was observed that an act of breach of trust involves
a civil wrong in respect of which the person wronged may seek his redress for damdges in a Civil
Court but a breach of trust with mens rea gives rise to a criminal prosecution as well.
3.3 The Supreme Court of India in Jaswantrai Maniklal Akhanev Vs State of Bombay {AIR SC 575
of 1956) held that a guilty intention is an essential ingredient of the offence of cheating. There·
fore, to secure conviction of a person for the offence of cheating, "mens rea·· on the part of that
person, must bEc established. It was also observed in Mahadeo Prasad Vs State of West Bengal
(AIR SC 724 of 1954) that in order to constitute the offence of cheating, the intention to deceive
should be in existence at the time of inducement was offered.
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3.4 Extrapolating on the above, the essential ingredients in order to constitute a criminal breach
of trust as defined in section 405 of !PC have been spelt out as, whoever, being in any manner
entrusted with property, or with any dominion over property:
{i) dishonestly or misappropriating or converts that propertv to his own use; or
(ii) dishonestly using or disposes of that property in violation:
of any direction of law prescribing the mode in which such trust is to be

discharged;
of any legal contract, express or implied, which he has made touching the
discharge of such trust; or
willfully sutters any other person so to do so commits "criminal breach of

trust".
3.5 The essential elements of fraud are listed below:
(i) False and wilful representation or assertion;
(ii) Perpetrator of representation;
(iii) Intention to deceive;
(iv) Representation must relate to a fact;
(v) Active concealment of facts;
(vi) Promise made without intention of performing it;
(vii) Representation must have actually deceived the other party;
{viii) Any other act fitted to deceive;
(ix} Any such Act or omission that the law specially declares as void; and
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{x) Wrongful Loss and Wrongful Gain 1s Immaterial
3.6 In the case of Navinchandra Vishnuprasad Shah Vs State of Gujarat (Cri GJ 1241 of 2013) the
High Court of Gujarat held that an offender must deceive, such deception must result into fraud•
ulent or dishonest inducement and a consequent delivery of a property or a consent in favour of
an offender to retain such property or an inducement to the person so deceived to omit to do or
to do a thing favourable to an offender and thereby exposing the per~on deceived to a loss of
damage or harm to his body, mind,. reputation or property etc.
3.7 It is imperative that to appreciate the contents of Section 420 of thEi IPC reference of St>ction
415 of the IPC is necessary as it provides for definition of cheating as contemplated in Section
420 of the !PC. The person must dishonestly or fraudulently induce the complainant to deliver
any property and the person should intentionally induce the complainant to do or omit to do a
thing. It is evident that a guilty intention is an essential ingredient of the offence ol cheating.
3,8 Judicial precedents have clarified it amply that allegations of fraud must be clear and specitic.
Mere suspicion or occurrence of events indicating out of the ordinary transactions cannot be
labelled as fraud.
3.9 It was held in the case of Padma Bewa v. Krupasindhu Biswal that in a sutt on the basis of
fraud, the allegation of fraud must be clear, definite and specific. General allegations of fraud,
unaccompanied by particulars, are insufficient to amount to an averment of fraud of which any
Court can take judicial notice. When fraud is charged against a defendant, it 1s an acknowledged
rule of pleading that the plaintiff must set forth the particulars of Lhe fraud which is alleged. It is
not enough to use such genera! words as 'fraud', 'deceit' or 'machin;:itions'. The circumstances
on which a plea of fraud is raised must be incompatible with the hypothesis ot good faith.
3.10 Further, the complainant has also used the words "criminal conspiracy". These words have
been defined in Section 120A of IPC as:
"When two or more persons agree to do, or cause to be done,
!1) an illegal act, or
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(2) an act which is not illegal by illegal means, such an agreement is designated a
criminal conspiracy:
Provided that no agreement except an agreement to commit an offence shall amount
to a criminal conspiracy unless some act besides the agreeme'1t is done by one or more
parties to such agreement in pursuance thereof.
Explanation.It is immaterial whether the illegal act is the ultimat,2 object of such agree-
ment, or is merely incidental to that object.]
It is further established that "The essential ingredients of the offence of criminal con-
spiracy are: {i) an agreement between two or more persons; (ii) the agreement must
relate to doing or causing to be done either (a) an illegal act; or (b) an act which is not
illegal in itself but is done by illegal means. It is, therefore, plain that meeting of minds
of two or more persons for doing or causing to be done an illegal act or an act by illegal
means is sine qua non of criminal conspiracy. - Rajiv Kumar v. State ot U.P., (2017) 8
sec 791".
3, '11 i~ccordtng1y, it is visible these vJords have been loosE~ly used bv the complainant i.;vfthout
substantiation of his assertion. In fact, through the entire compliant, the complainant has at-
tempted to sensationalise his comments and has even mislead the Disciplinary Directorate by
misrepresenting the facts and/or distorting the facts. This only serves to establish the nefarious
intent of the complainant in tarnishing the good image and reputation of the respondent and his
firm. ICAI ought to reject complaints of this nature outright.
3.12 The complainant has stated that the respondent was also responsible for giving assurance
to foreign investors on the consolidated accounts of IREO Group which was signed at Mauritius
leveL
3.13 The complainant has himself served as CEO of IPL and would be aware of tt1e fact how the
entities of the company have been structured in different countries. Although the complainant
has made this assertion he has not referred to this issue in the list of 17 (seventeen) allegations
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included by him. This is a pure and simple instance of the mischief of the complainant. It needs
to be noted:
i) That the firm of the undersigned was not engaged by any foreign entity.
ii) That the undersigned or his firm was not responsible for providing any
report to the auditors of the entities in Mauritius.
iii) The auditors of the various entities in Mauritius did not correspond wilh
the undersigned or his firm requiring any report for consolidating any ac-
counts in Mauritius
3.14 The complainant has further stated that the respondent had acted fraudulently with the
management in certifying false statements of accounts, hiding vital information from the in
vestors, more particularly government departments, in order that tax evasions are not de
tected. These are merely baseless statements of the complainant; wherever and whatever has
been stated by the complainant as allegations against the respondent, the same have been
dealt 'Nfth in details+ Each of the allegations !evied by the compJainc:nt are expressly denied,
and should not be construed to be accepted under any circurnstanCE!S, Further the complain-
ant has not produced any proof or evidence where such falsificatior of account or any other
Jct in contravention of the law has been upheld against the respondent or his firm
3.15 In Para B of the introductory part of his attachment to the complaint, the complainant
has stated as follows:
"IREO Group has suffered massive frauds, done by local management team, it may be re-
called that in December 2019 Disciplinary Directorate of !CAI had declared (iUlLTY all four
statutory auditor of IREO Group and also senior managers of lREO Group."
3,16 ln this respect it may be noted:
i) The complainant has filed complainants against other members ICAI, who were auditors
of IPL and other SPVs.
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ii) The respondent is naturally not in any way responsible/answerable for the complaints
against such other members filed by the same complainant.
iii) The respondent has however found from reliable sources that the contention of the com-
plainant the Disciplinary Directorate has declared all four statutory auditors guilty of pro
fessional misconduct is a false and misleading statement
iv} The complainant is a habitual litigant and has filed more complaints than perhaps any
other individual would have done in his personal capacity, and would be expected to know
that the prima facie opinion of the Director (Discipline) and the, declaration of members
of ICAI held guilty are two entirely drfferent things. The complainant is in a clear cut habit
of maligning chartered accountants. He should be put to strict test to prove that the con·
tents of his assertions.
v} The complainant has blatantly misled the Institute with a dear cut intention to sensa
tionalise his complaint.
3.17 !n Para C the complainant has stated cis fo!k.iws·
"It: is submitted with full responsibility and accountability that all these frauds could have
been easily avoided had the statutory auditors of IREO Le Mr. Vine•sh Jain and the firm S.
N. Dhawan & Company has duly discharged their statutory and legal duties and responsi-
bilities as required under the Companies Act."
3.18 It is evident that when the complainant is mentioning "these frauds, he is referring to
"frauds" referred in Point 3.14 above. There is a dear cut distinction between the responsibHities
of each auditor; each auditor is responsible for his/her own report and cannot be made respon,
sible for the work of others. The firm of the undersigned has been engaged as the auditor of
lREO Private Limited and certain SPVs for the following years as below:
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s. Engagement and signing

Company Name
No. Partner
2018-19 2017~18
l lreo Private Umited Vinesh Jain Vinesh Jain
2 lreo Residences Company Private limited Vinesh Jain Vinesh Jain
3 lreo Victory Valley Private Limited Vinesh Jain Vinesh Jain
4 IREO Grace Realtech Private Limited Vinesh Jain Vinesh Jain
5 lreo Hospitality Company Private Limited Vinesh Jain Vinesh Jain
6 G.P.Realtors Private Limited Vinesh Jain Vinesh Jain
7 Onehub (Chennai) Private Limited Vinesh Jain Vinesh Jain
8 IREO Fiveriver Private limited Vinesh Jain Vinesh Jain
9 !REO Management Private Limited Bhaskar Sen Bhaskar Sen
10 Orchid IREO Realty Private Limited Bhaskar Si;m Bhaskar Sen
11 Limitless Knowledge Private Limited Bhaskar Sen Bhaskar Sen
12 Accent Builders Private Limited Bhaskar Sen Bhaskar Sen
13 Glazy Realty Private Limited Bhask,H Sen Bhaskar Sen
14 Rago Realtors Private Limited Bhaskar Sen Bhaskar Sen
15 Sunflower Real Tech Private limited Bhaskar Sen Bhaskar Sen
16 Angel Propbuild Private Limited Bhaskar Sen Bhaskar Sen
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17 Evolution Realty Private Limited Bhaskar Sen Bhaskar Sen
18 Faith Buildtech Private Limited Bhaskar SE~n Bhaskar Sen
19 Elite Township Private Limited Bhaskar Sen Bhaskar Sen
20 Proud Buildwell Private Limited Bhaskar Sen Bhaskar Sen
21 Wisdom lnfrahome Private Limited Bhaskar Sen Bhaskar Sen
3.19 From the above, it is evident that the respondent can be held responsible for which he was
the engagement partner for the year 2017-18 and 2018-19.The assertion of the complainant that
the frauds which he referred in his complaints against other auditors about which the respondent
has no details, and neither is the undersigned connected with the audit of the en lilies in those
years, cannot be used to make the undersigned liable for professional misconduct. The assertion
of the complainant referred above is thus ridiculous.
3.20 ln Para D the complainant has stated as follows:
"Sri Vinesh Jain, Partner of S. N. Dhawan & Company was grossly negligent in conducting
the audit besides being part of frauds and illegal acts enumerating below. It is a fit case
of imposition of Section 447 of Companies Act. Under Section 447, it may be noted that
auditor may become liable upto 300% of the amount of fraud as well as prosecution.
a} ln auditor report and CARO, Non Reporting of evasion of GST /Service Tax is a gross
violation of rcportine, under the (ompnnies Act, 201.3."
A statutory <e1uditor is fully awJre of the requirements of disclosures :equired in the annual re
ports/Balance Sheet. Mr. Vinesh Jain statutory auditor of IREO Group of' Companies from S. N.
Dhawan & Company has violated all disclosure requirements RELATED TO THE NON PAYMENT/
EV.l\S!ON OF SERVlCE TAX / GST OF !REO group for various transactions. In his signed Balance
/ 17
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Sheet of IREO Group for 2017-18 and 2018-29, he has deliberately helped IREO to hide transac-
tions and tax evasion. CARO is silent on any amount due which needed reporting of unpaid
GST/Service Tax.
3.21 Section 447 of the Companies Act, 2013 contains the following provisi,on with respect to the
meaning of fraud:
For the purposes of this section-
(i) fraud .in relation to affairs of a company or any body corporate, includes any act, omis-
sion, concealment of any fact or abuse at position committed by any person or any other per•
son wrth the connivance in any manner, with intent to deceive, to gain undue advantage from,
or to injure the interests of, the company or its shareholders or its creditors or any other per-
son, whether or not there is any wrongful gain or wrongful loss;
{ii} wrongful gain means the gain by unlawful means of property to which the person gain
ing is not legally entitled;
(iii) wrongful loss means the loss by unlawful means of property to which the person losmg
is legally entitled.
If there is any violation of Section 447 of the Companies Act, the same would have to be dealt
with by a differcmt judicial process before a different forum. The Disciplinary Directorate of ICAI
is not the forum to deal with contraventions of Section 447.
The complainant has intentionally included these comments herein in an attempt to justifiably
tarnish the good name and reputation of the respondent and his firm. Making such comments
while relating to professional misconduct by the respondent under the disciplinary mechanism
of !CA! is neither relevant nor acceptable as an allegation. At the cost of repetition, the complain-
ant has merely attempted to sensationalise the introduction to his allegations.
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3.22 In Para - F complainant has stated as follows:
"!t is brought to the notice of ICAJ, that GST Department has already summoned Mr.
Vinesh Jain and recorded his statement & also collected information related to the tax
evasions. Affidavits filed by GST Department in the Hon High Court (Hon HC) are showing
huge tax evasions by lREO Group, which ultimately proves non disclosures by Mr. Vinesh
Jain in auditors report and CARO."
3.23 Two issues have been raised by the complainant, namely recording of the <;tatement by the
GST department after summoning the auditor, and affidavits filed by the GST department in the
Honourable High Court. With respect to the recording of the respondent, we believe that the
respondent, as a law abiding citizen of the country, appropriately despondent by appearing be-
fore the GST department; by recording his statement he has done nothing which is against the
law; the respondent clearly remembers that there was nothing contained in his statement
which established the baseless assertions of the complainant; the undersigned does not have a
copy of his recorded statement, but if the Disciplinary Directorate so requires, such copy may be
obtairred frorn the GST department. As far as the filing of the affidavits bv
concerned, the complainant has not produced any copy of the same, and without the perusal of
any particular document the respondent cannot make an appropriate r,omment. Further, the re-
spondent had appeared before GST department towards the beginning of 2020, and if the aff1
davits by the GST department have been filed thereafter, such documents were neither available
nor would have been studied by the auditor before finalising his report and completing the audit
procedures relevant to the financial year 2018-19. The entire assert,on of the cornpl;,inant is
meaningless as far as the question of professional misconduct by a mernber of !CAI is concerned.
3,24 In Paras G, H, I & J the complainant has stated as follows:
Para -G- In the public interest and in the interest of revenue to the government of India,
I have sent questions to Mr. Vinesh on email and requested him to respond in 15 days
(Pages 160 to 168). I also followed up. These questions and clarifications are related to
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tax evasion by !REO Group/loss to public exchequer and hence l request him to co-oper-
ate. But he simply did not respond.
Para - H - Mr. Vinesh Jain needs to answer each and every question given below as each
question is related to a different time period or different aspect of accounting or tax eva
sion to !CAL FOR EASY OF ANSWERING AND ALSO TO BRING OUT THE TAX EVASION
CLEARLY. QUESTIONS HAVE BEEN FRAMED AFTER EXPLAINING THE EACH TAX EVASION
CLEARLY.
Para -1-Vinesh Jain must submit in writing the detailed reasons why he failed to disclose
the unpaid amount to Central Government and kept quiet in CARO reporting resulting m
professional negligence of highest order
Para - I - With above background, we give details of defidencies observed in reporting
requirements by Vinesh Jain, as required by !CAI/MCA regulations.
3.25 The undersigned states and submits:
i} As the statutory auditor, the respondent is not required to deal with the queries
any/every individual may pose him with respect to the transactions of his cliPnt,
and which may relate to information that has been gatherE:d by the auditor in the
discharge of his professional duties.
ii} Section 100.4{d) of the Code of Ethics states as follows:
"Confidentiality
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A professional accountant should respect the confidentiality of information ac-
quired as a result of professional and business relationships and should not dis
close any such information to third parties without prooer and specific authority
unless there is a legal or professional right or duty to disclose. Confidential infor.
matlon acquired as a result of professional and business relationships should not
be used for the personal advantage of the professional accountant or third par
ties."
iii) Clause 1 of Part 1 of the Second Schedule to the Chartered Accountant Act states
as follows:
"A chartered accountant in practice shall be deemed to be guilty of professional
misconduct, it he-
(1) discloses information acquired in the course of his professional engage
ment to any person other than his client so engaging him, without the con-
sent of his client or otherwise than as required by any law for the time be-
ing in force."
iv) 1n view of the above, the statutory auditor is required to maintain confidentiality
and cannot respond to the individual communications, more so when communi
cation is being made by an individual who is currently engaged in litigation with
the client
v) Under the disciplinary mechanism of !CAI, the respond!mt shall respond to the ai
legations that may be levied against him; the respondent is not bound to answer
"each and every question" posed by the complainant.
vi} While we deal with each of the allegations that the complainant, it becomes evi
dent that the complainant is looking for more information and this entire initiative
appears to be in the nature of phishing inquiry to gather more details about the
client of the undersigned.
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vii} lt is now a settled principle of law th;ough the judicial pronouncement in Madhya
Pradesh High Court Oder ot Council Of The Institute Of ... vs C.H. Padliya And Co.
And Ors (1979 49 CompCas 478 MP}.
'The charge of misconduct implies dishonesty and mental condition of the con
cemed chartered accountant. The chartered accountant cannot prove something
which is of a negative character to disprove the charge. He may lead evidence, oral
and documentary, to establish his stand or throw reasonable doubt about his guilt
of any misconduct so as to entitle him to have the complaint dismissed However,
the onus is on the authority or the person that charges or complains against the
chartered accountant of any misconduct to prove the S<1me beyond reasonable
doubt by adducing legal and satisfactory evidence, oral and documentary. The lr:-
gal practitioner has no duty to disprove the charge, if there is ro material worth
mentioning to prove his guilt."
3.26 ln view of the above, the complainant is required to state the allegations and provide proof
in support of the stirr1e. :n absolute derogation of the principle referred above, the ccmp!a!nant
has made assertions that he can ask questions from a member of lCAt using the forum of the
disciplinary mechanism of the Institute. The respondent, in subsequent paragraphs, would re-
spond to each of the allegations that are supported with proof/evidence and may require to be
dealt with in an inquiry under Section 21 of the Chartered Accounts Act and the applicable Rules;
in cases where no proof or evidence is attached, the respondent shall point out the same; and
in cases where the complainant has resorted to asking questions so that he may decide at a later
date the future his course of action, the respondent is under no obligation to respond to such
queries.
3.27 It is specifically submitted that the contents of the subsequent Pa,·ts ,::if this submission are
without prejudice to what has been stated in the preceding paragraphs. The respondent specifi
cally prays that the preliminary issues be settled before any of the sc called charges are even
considered by the Director (Discipline). The respondent reserves the right to file his detailed and
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comprehensive written statement once he is aware of the Clauses/Parts of the relevant Sched
ules to the Chartered Accountants Act under which he is charged for professional misconduct.
3.28 We now start dealing with each of the so called charges levied by the complainant. It is
specifically stated and submitted that although the complainant used lhe word "charge", he has
not referred to any Clauses/Parts of the two Schedules to the Chartered Accountants Act A
charge of professional misconduct would have to be with reference to one or more of the various
parts to the two Schedules of the Chartered Accountants Act. As has been referred in the pre
ceding paragraphs, this inquiry could not have even proceeded without the complainant having
specified the Clauses/Parts of the two Schedules he is alleging profe~.sional misconduct by the
undersigned. Further, the Director Discipline has not opted for getting the complaint rectified,
and thus these proceedings are void ab initio.
B. Response to the charges with prejudice to contents of preceding garagraphs
4. Charge-1
4.1 The complainant refers to "IREO Group of Companies". We are not aware of what his inten
tions are and what he means by the words "Group of Companies". The complainant has nowhere
specified what he believes or considers to be "!REO Group of Companies". Further still, the corn
p!aimmt on Page 169 of his complalnt document has referred to 20 entities under the heading
"!REO Gro,up of Companies" audited by Mr. Vinesh Jain. The undersigned draws your attention
to the contents of Para 3.18 above wherein it has been explicitly clarified that the respondent
has been the signing partner of only a limited number of entities and not 20 entities as alleged
by the complainant. It is thus blatantly visible that the complainant i~; not aware of the facts ot
the case, and thus make of his assertions cannot be acceptable.
4.2 The respondent vehemently denies and disputes charge No: 1 for additional reasons as spec-
ified below.
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4.3 This particular charge is more in the nature of an explanation of the understanding of the
complainant with respect to Cenvat Credit Rules of Service Tax. He has further referred to the
financial statements for the years 2014,.15 and 2015·16 of !REO Priva:e Umited (IPL). lt may
specifically be rnentioned that the respondent was not the auditor of IPL during 2014-15 and
2015-16.
4.4 To be more precise there is nothing in the nature of an allegation in the so called Charge ·· 1
levied by the complainant
4.5 The complainant has referred to documents of the audit file of the respondent and has at-
tached some documents on Pages 44 and 45. All audit files are the pronerty of the auditor, and
the undersigned specifically submits that he did not provide the copies attached on Pages 44 and
4S to the complainanL Accordingly, it is apparent that the complainant has resorted to theft ot
documents which are the property of the respondent and his firm. First of alt, the complainant
must come with clean hands to state how he obtained such copies failing which it shall only fur-
ther confirm the character and intentions of the complainant; and that alone shall provide
enough reason for the Disciplinary Directorate not to place any reliability on the assertions of the
cornpla1nant
4.G It is further submitted that the understanding of the complainant with relation to the Cenvat
Credit Rules of Service Tax Act are totally misleading. The decision in M/s. Alembic Ltd. And
Shreno Ltd. Versus C.C.E & S.T. Vadodara-1 (2018 (10) TMI 1557 · CESTAT /\HMEDABAD) clarifie,;
the tallowing:
"13. We agree with such plea raised by the Appellant. While the law does not intend to
allow any undue benefit to a service provider in terms of Cenvat Credit of Service Tax paid
on input services used in providing non-taxable output activity, however, as held by the
Hon'ble Apex Court in the case of Dai lchiKarkaria 1999(112} El.T SJ6(SC), Modvat / Cen-
vat Credit is a vested right. Once it is legally and validly availed, the sarne cannot be denied
and/or recovered unless specific provisions exist for the same. The Appellants have also
correctly relied Lipon the decisions/ judgments in the case of HMT Ltd., TAFE, Ashok Iron
& Steel Fabricators (supra} wherein an identical situation qua "inputs" used in production
t
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of dutiable finished goods was involved, where on a particular date, the said Finished
goods became exempt and the issue involved was as regards er-edits availed at a time
when such Finished goods was otherwise dutiable.
14. It has been a consistent judicial view, including that of the Hon'ble Apex Court in such
cases,. that credit entitlement is on the date of receipt of inputs when the output activity
was wholly dutiable. Merely because the finished goods eventually became exempt later
on, the credit availed on inputs which were contained in semi••finished / finished goods
state was held as not deniable. The present case is squarely covered v1de such ratio laid
down by higher courts.
15. In foct, in order to overcome such legal position, transitional provisions were intro•
duced in the Modvat/Cenvat Credit Rules. That Rule 1.1 of the Cenvat Credit Rules, 2004
as it existed during the materfal period, provides that where any inputs are contained in
semi-finished or finished goods form, as on date when the finished goods becomes ex
empt or output services become exempt, such credit will have to be reversed. As clarified
vide TRU clarification No.334/1/2007-TRU dt.28.2.07 and also taken note of by Hon'ble
Madras High Court in the case ofTAFE 2015(320) ELT 357(Mad) and eventually upheid by
Hon'ble Apex Court 2015(324) ELT A86{SC), such embargo applies only to inputs and not
to input services at all. Admittedly, in the present case, the dispute is limited to credits
availed on input services during a time when output service was whoily taxable howt",ver,
portion thereof became non- taxable on account of receipt of Completion Certificate later
on.
16. This being the case, a harmonious reading of Rule 3 of the CCR, 04 read with Rule 6
and Rule 11 of the said Rules will suggest that eligibility/ entitlement to credit has to be
examined only at the time of receipt of input service and once it is found to be availed at
a time when output service is wholly taxable, and the said credil is availed legitimately .
the same cannot be denied and/or recovered unless specific machinery provisions are
made in this regard. As per above TRU clarification dt.28.2.07, even if one assumed sale
of immovable property after Completion Certificate to be "exempt service" even going by
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the findings in the impugned order, even then there is no legal requirement to reverse
any credit availed on "input services" in the past (prior to obtaining Completion Certifi
cate) at all.
17. The Ld. Counsel for the Appellants had also tried to compare the present position to
one where "remission of duty" is granted on finished goods in case the same is destroyed
or lost as well as when services are provided to the state of J&K, however, considering
the fact that legally, the credits availed at a time when output service was wholly taxable
as well as the fact that after receipt of completion certificate, the Appellants have anyway
availed only proportionate credit by maintaining separate accounts, such other pleas
need not be adverted to.
18. From the analysis of all the legal provisions for the purpose of Cenvat Credit in respect
of input service, we find that before obtaining the completion certificate, the service of
the appellant was very much taxable during which period the appellant received input
service. The relevant sub Rule (7) of Rule 4 of Cenvat Credit Rule:;, 2004 reads as under:-
Rule 4(7)
4(7) The Cenvat Credit in respect of input service shall be allowed, on or after the day on
which the invoice, bill or as the case may be, challan referred to in Rule 9 is received:
Provided that in case of an input service where the service tax is paid on reverse charge
by the recipient of the service, the CENVAT credit in respect of such input service shall be
allowed on or after the day on which the payment is made of the valve of input service
and the service tax paid or payable as indicated in invoice, bill or., as the case may be,
chaHan referred to in Rule 9:
Provided further that in case the payment of the value of input service and the service tax
paid or payable as indicated in invoice, bill, or as the case may be, challan referred to in
Rule 9, is not made within three months of the date of the invoice, bill, or as the case may
be challan, the manufacturer of the service provider who has taken credit on such input
service, shall pay an amount equal to the cenvat credit availed on such input service and
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in case the said payment is made, the manufacturer or output s1::rvice provider, as the
case may be, shall be entitled to take the credit of the amount equivalent to the CENVAT
credft paid earlier subject to the other provisions of these Rules:
Provided also that if any payment of part thereof, made towards an input service is re-
funded or a credit note is received by the manufacturer or the 5ervice provider who has
taken credit on such input service, he shall pay an amount equal to the CHJVAT credit
availed in respect of the amount so refunded or credited:
CENVAT credit in respect of invoice, bill or as the case may be, challan referred to in rule
9 issued before the first day of April 2011 shall be allowed, on or after the day on which
payment is made of the value of input service and the service tax paid or payable as indi-
cated in invoice, biH or, as the case may be, challan referred to in :Rule 9.
Explanation -l
The amount mentioned in this sub rule, unless specified otherwise, shall be paid by the
manufacturer of goods or the provider of output service by debiting the CENVAT credit or
otherwise on or before the fifth d;:iy of the following month except for the month of
March_. when such payment shall be made on or before 31stM.arch.
Explanation -II
If the manufacturer of goods or the provider of output service , fails to pay the amount
payable under this sub rule , it shall be recovered , in the manner as provided in rule 14,
for recovery of CENVAT credit wrongly taken,
Explanation -lll
In case of manufacturer who avails the exemption under a notification based on the value
of clearance in the financial year and service provider who is an individual or proprietor
ship firm or partnership firm , the expression, "following month" and the "month of
March" occurring in sub rule- 7 shall be read respectively as "following quarter" or "quar-
ter ending with the month of March"
_,
)'7
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From the above rule, it is clear that the assesse is not required to wait till output service
is sold to the service recipient. The assesse can take the credit immediately after the day
on bill/ chal!an of input service is received, In the present case, there is no dispute that
the appellant have availed the credit after receipt of bill, challan in respect of input ser,
vice, therefore, the appellant was legally entitled to take the credit on the date after the
receipt of service Bills/ Chal!ans. Therefore, the availment of cenvat credit by the appe!,
!ant is absolutely legal and correct in accordance with Rule 4(7) of Cenvat Credit Rules,
2004. At the time of taking credit, there is no existence of any exempted service, there
fore, there is no application of Rule 6. The part of the service was exempted only after
obtaining completion certificate. Thereafter, the appellant was not required to aval! the
cenvat credit on the input service, if any, received after obtaining the completion certifi-
cate. In the present case, the appellant have either not availed the cenvat credit in respect
of the services received after obtaining the completion certificate in respect of exempted
service or availed proportionate credit attributed to the taxable output service, For this
reason also Rule 6 has no application for the period after obtaining the completion Cer,
tificate.
in case of service becomes exempted at a later stage, unlike the provision for manufac
tured goods provided under Rule 11(1)(2) and (3), there is no sJch provision in respect of
the service. The only provision for the service is provided under Sub-Rule (4) of Rule 11
which reads as under:
"11(4) A person provider of output service shall be required to pay an amount equivalent
to the CENVAT credit, if any, taken by him in respect of inputs received for providing the
said service and is lying in stock or is contained in the taxable service pending to be pro
vided, when he opts for exernption from payment of whole of the service tax leviable on
such taxable service under a notification issued under section 93 of the Finance Act, 1994
(32 of 1994) and after directing the said amount from the balance of CENVAT credit, if
any, lying in his credit, the balance, if any, still remaining shall lapse and shall not be al-
lowed to be utilized for payment of duty on any excisable goods, whether cleared for
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home consumption or for export or for payment of service ta>: on any other output ser-
vice, whether provided in India or exported."
from the above sub rule (4), it can be seen that even if an output service provider avail
the credit and output service becomes exempted in such case the credit only in respect
of inputs lying in stock or is contained in taxable service is required to be paid whereas
there is no provision for payment of cenvat credit equivalent to the input services used in
respect of exempted service. Therefore, the cenvat credit availed in respect of input ser-
vice is not requfred to be paid back under any circumstances.
19. We accordingly hold that the Appellants were not legally required to reverse any
Credit which was availed by them during the period 2010 ti!! obtaining Completion Certif-
icate, i.e. during the period when output service was wholly taxable in their hands, merely
because later on, some portion of the property was converted into immovable property
on account of receipt of Completion Certificate and on which no Service Tax would be
paid in future.
4.7 ln the above referred case the judgment clearly states:
"5. The present appeals involves the following legal questions:
a. Whett1er receipt ot consideration for residential units sold as immovable property
after receipt of completion certificate amounts to providing exempted service and
Rule 6 of the CCR, 04 is applicable in such case and as such, whether the Appellant~
are liable to pay 8%/10% amount of exempted value under Ru!e 6 of the CCR, 04?
b. Whether Credit can be allowed to the Appellants under Rule 3 of the CCR, 04 in
such circumstances?
c. Whether the Appellants can be said to have "maintained proper separate ac-
counts" as required under Rule 6 of the CCR, 04?
29
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d. Whether the Appellant~ are required to reverse Cenvat Credit availed dunng the
period when output service was taxable before receipt of Completion Certificate,
since such services were availed to construct entire propEirty, and portion of such
property did not attract Service Tax after receipt of Completion Certificate?
e. Connected to the question (d), whether the Appellants are eligible to seek refund
of the amount paid under protest towards Credit availed from ?.010 till receipt of
completion certificate, based on CERA audit objection wh,Jrein such credit was
sought to be reversed based on considering square foot area where Service Tax
was paid and balance area where Service Tax will not be paid after Completion
Certificate.
4.8 With respect to the questions raised the same judgment states:
"24. The specific questions framed in this regard therefore have to be answered as fol.
lows:
a, For the above reasons, the Appellants are not liable tc, pay 8%/IOW, amount of
value of service became exempted after receipt of completion certificate under
Rule 6 of the CCR, 04,
b. The Cenvat Credit on input services received after obtaining Completion Certifi•·
cate cannot be wholly allowed to the Appellant, and since they had availed only
proportionate credit by maintaining separate accounts, the same is therefore suf-
ficient compliance of the legal obligation cast upon them.
c The Appellants can be said to have "maintained proper separate accounts" as re
quired under Rule 6 of the CCR, 041 having availed credit only to the extent input
services in taxable activity, on the scientific basis after obtaining Completion Cer
tificate.
10
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d. The Appellants are not required to reverse Cenvat Credit availed during the period
when output service was wholly taxable before receipt of Completion Certificate,
in accordance with law.
e. Connected to {d) above, the Appellants are eligible to seek refund of the amount
paid under protest towards Credit availed from 2010 till rece.ipt of completion cer
tificate, based on CERA audit objection wherein such credit was sought to be re
versed based on considering square foot area where Servic1? Tax was paid and bal-
ance area where Service Tax will not be paid after Completion Certificate, in ac-
cordance with law.
4.9 Your attention is also drawn to the extract of the Supreme Court judgement in the cnsc of
CCE, Pune vs. Daiichi Karkaria ltd. [1999 (112) ELT 353; decided on 1LB.99J
"It is clear from these Rules, as we read them, that a manufacturer obtains credit for the
excise duty paid on raw material to be used by him in the production of an excisable prod-
uct immediately it makes the requisite declaration and obtains an acknowledgement
thereof. It is entitled to use the credit at any time thereafter when making payment of
excise duty on the excisable product. There is no provision in the Rules which provides for
a reversal of the credit by the excise authorities except where it has been illegally or ir •
regularly taken, in which event it stands cancelled or, if utilised, has to be paid for. We
are here really concerned with credit that has been vaHdly tak,m, and its benefit is avail
able to the manufacturer without any limitation in time or otherwise unless the manufac
turer itself chooses not to use the raw material in its excisable product. The credit is.,
therefore, indefeasible. It should also be noted there is no co-relation of the raw material
and the final product; that is to say, it is not as if credit can be ti:'l<en only on a final product
that is manufactured out of the particular raw material to which the credit is related. The
credit may be taken against the excise duty on a final product '17anufactured on the very
day that it becomes available."
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4.10 The above refers to judgment of the Hon'ble Supreme Court has also been cited in the Guid-
ance Note on accounting treatment for Modvat/Cenvat published by lCAI. From the above it is
abundantly dear that a business entity would be justified in not reversing the credit already
availed before obtaining the Completion Certificate during the regime of the Service Tax Act
However, from the initiation of the regime of GST the law made it dear t:ciat such reversal would
have to take place. It has to be further understood with abundant clari:y that by not reversing
the credit already availed during the regime was a general industry practice; that had lead to
litigation with the department which was settled in the case referred above was delivered.
4.11 The dispute was considered by Tribunal in Alembic limited (supra). Relyi.ng on decision ot
Supreme Court in Collector v. Dai lchi Karkaria limited, 1999 (112} ELT 353 {SC), it was held that
the entitlement to Cenvat credit is to be determined at the ti me of receipt of input services and
merely because the output services became exempt later on, the credit on input services re-
ceived earlier is not deniable, in the absence of specific provision. The Tribunal also considered
Rule 11 of the Cenvat Credit Rules, 2004, which specifically provides for reversal of credit on
inputs in case of finished goods/ output set-v1ces becorning exernµt later. For illustration, Rule
11(4) provides for reversal of credit in respect of inputs received for providing output services,
Nhen the service provider opts for exemption from payment of Service Tax on such output ser-
1
vices. Highlighting the absence of such specific provisions in the context ot C:envat credit on input
services, it held that eligibility/entitlement to credit has to be examined only at the time of re-
ceipt of input service and once it is found to be availed at a time when output service is wholly
taxable, and the said credit is availed legitimately, the same cannot be denied and/or recovered
unless specific machinery provisions are made in this regard. Aggrieved by the said decision of
the Tribunal, the Department preferred an appeal before Gujarat High Court, which was dis
missed in Alembic Limited (supra).
At the cost of repetition, it is stated again that there is no allegation of professional misconduct
against the undersigned in the so called charge No: :L
f 32
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5. Charges - 2, 3 & 4
5.1 The complainant has produced the charge in the complainant document in a rectangular box
and followed it up with certain questions and comments. The responde'1t vehemently denies and
disputes charge No: 2, 3 & 4 for reasons as specified below.
5.2 The first issue that the respondent wishes to clarify is that there is a difference between non-
payment and not reversing the credit. The two are entirely different things and the complainant
has utterly confused the two, presumably believing them to be synonymous.
5.3 Your reference is drawn to the contents of the submission under charge 1 which clarified the
genera! practice of the industry, the accounting treatment in accordance with the Guidance Note
issued by ICAf and finally the resolution through the judicial pronouncement in Alembic Case.
5.4 For Service Tax purposes it was held that the entitlement to Cenvat credit is to be determined
at the time of receipt of input services and merely because the output services became exempt
later on, the credit on input services received earlier is not deniable, in the absence of specific
provision. The Tribunal also considered Rule 11 of the Cenvat Credit R:;;les, 2004, which specifi-
canv provides for reversal of credft on inputs in case of finished goods/ output sePlices becoming
exempt later. For illustration., Rule 11(4) provides for reversal of credit in respect of inputs re-
ceived for providing output services, when the service provider opts for exemption from payment
of Service Tax on such output services. Highlighting the absence of such specific provisions in the
context of Cenvat credit on input services, it held that eligibility/entitlement to credit has to be
examined only at the time of receipt of input service and once it is found to be availed at a time
when output service is wholly taxable, and the said credit is availed legitimately, the same cannot
be denied and/or recovered unless specific machinery provisions are made in this regard.
5.5 In case of Skyon, OC was received on 14 th September 2017 and the OC for Victory Valley was
received on 28 September, 2017. As far as the treatment in respect of Cenvat Credit claimed
under Service Tax is concerned, detailed explanzition has been provided above. ft may further be
noted:
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1. As per Rule 43 of GST rules, Input tax credit has to be reversed on receipt of Completion
certificate or first occupation of the project.
2. On receipt of OC, obligation on the Company was to reverse input credit. The Company
has sufficient input credit as on date of OC.

, .........
···~·
Name of Com- Input credit as at Input credit as at Reversal lnpu·
pany 31 March, 2018 31 March, 2017 made in credi
2018-19 31.3.
W"•"•'>'w _ _ , _ __.,,,, ~~'""'

·-·
lacs Rs. Lacs Rs. Lacs Rs. Lacs
...._.,,,
!reo Private Um- 2438 1171 825 2344
!ited I
""""'" ,,.,_,""""''''~""
I
lreo Victory Valley 570 1302 l 300 445
:
.-,---
I ,_H_µ~•~,,.,_.,.,M<n,<<
_L '"~~
Schedule 7 to Financial Statements of IPL for 2018--19 and 2017..\8 attache·d at page 106 and
107
Schedule 14 and 13 for financial years 2018-19 and 2017 18 respectively of financial statement
of treo Victory Valley attached at page 108 and 109
5.6 As per CARO reporting requirement for the relevant year the auditor is required to state as
follows:
"Whether the company is regular in depositing undisputed statL:tory dues including prov
ident fund, employees' state insurance, income-tax, sales-tax, service tax, duty of cus
toms, duty of excise, value added tax, cess and any other statutory dues to the appropn
ate authorities and if not, the extent of the arrears of outstanding statutory dues as on
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117
the rast day of the financial year concerned for a period of more than six months from the
date they became payable, shall be indicated; [Paragraph 3{vii)(a)]"
5.7 Your attention is specifically drawn to the contents of Para 42K contained in the Guidance
Note issued by ICAf with respect to CARO 2016:
"The report should be restricted to the actual arrears and should not include the amounts
which have not fallen due for payment to appropriate authority and have been recognised
as outstanding dues at the balance sheet date."
5.8 As part of the Guidance Note of ICAI, an auditor is required to ensure the following:
Audit Procedures and Reporting
(m) The auditor should make plans to test whether the company is regular in depositing un-
disputed statutory dues. The auditor, in order to be able to comment on this clause,
should have a general understanding of the various statutes governing the company and
the dues payable by the company under those statutes. The auditor should also enquire
of the management of the company about the statutes under which the company is
required to pay any statutory dues. The auditor should also discuss with the manage-
ment. the policies or procedures adopted for identification and payment of stat,t,1!9.LY
dues. The auditor may also obtain from the management or himself prepare a calendar
of dates for submission of various statutory dues by the company for his reference.
(n) The information necessary to comply with this requirement of the Order may be obtained
from the company in the form of a statement. The statement should contain a list of
various statutes under which the company is required to make payments regularly to
3:!Jwropriate authorities, the kind of payments under each statute, the due date for mak
ing the payment to the appropriate authority, the date on which the payment is rnade by
the company, the arrears not due and the arrears overdue for more than six months. The
auditor should verify the statement provided by the management with the underlying
documents and records. The auditor's general understanding of the various statutes gov-
erning the company and the dues payable by the company under those statutes would
35
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118
help the auditor in assessing the completeness of the statement. The auditor should rec-
ognise that there could be a situation that a statutory due might have become payable
but has not been captured by the accounting and internal control systems established by
the enterprise and, therefore, the auditor should perform procedures to mitigate risk aris-
ing from such a situation.
(o) The auditor should obtain a written representation with reference to the date of the
balance sheet from the management: {Emphasis provided)
5.9 The respondent had accordingly ensured the following:
• Understanding of Service Tax and GST Rules regarding completion of real estate project
and treatment of input credit
• There were different opinions regarding reversal ot Service Tax input credit on complEi
tion of project.
• Analyzed, whether any reporting in CARO is required. As per reporting requirements, any
payment which is outstanding for more than 6 months is to be reported.
• Verified, Input credit available with the Company {as tabulated above).
• It was concluded, that no payment is due even in case of wor5t situation of reversal of
service tax and GST.
• GST authorities has visited lreo office on 18 October, 2019. The GST authorities made the
Company to reverse Input credit relating to completed projects of Skyon, and Victory
Valley. The amount reversed on 18 October, 2019 was Rs. 825 !akhs in !reo Private lim-
ited (IPL) and Rs. 300 lakhs in lreo Victory Valley Private Umited
• Since the Company has made reversal on 18.10.2019, we asked the Company to take
provision in the financial statements of 2018-19. Accordingly, amount of Input credit was
reversed in 2018-19 and charged to profit and loss account
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119
• We have verified the calculation of reversal of Input credit (Copy of work paper attached
at Page No. 110}. We had taken details of sold and unsold area and verified calculation.
• IPL has net loss of Rs. 50,099 !akhs and total assets of Rs. 450,549 lakhs for 201819. Input
reversal of Rs. 825 lakhs comes to 1.6% of loss and 0.2% of assets. It was not considered
material and hence no disclosure was considered necessary in financial statements. Copy
of balance sheet and profit and loss of IPL attached at page No. 111 -112)
5.10 While reviewing the provisions under Cenvat Credit Rules, the auditor was fully aware ol hi'.>
obligations under SA 250 which stated as follows:
SA 250
5. The auditor is responsible for obtaining reasonable assurance that the financial statements,
taken as a whole, are free from material misstatement, whether caused by fraud or error.
In conducting an audit of financial statements, the auditor takes irto account the applicable
legal and regulatory framework. Owing to the inherent limitations of an audit, there is an
unavoidable risk that some material misstatements in the financial statements may not be
detected, even though the audit is properly planned and performed in accordance with the
S!\s. In the context of laws and regulations, the potential effects of inherent limitations on
the auditor's ability to detect material misstatements are greater for such reasons as the
toll owing:
0 There are many taws and regulations, relating principally to the operating aspects of an
entity that typically do not affect the financial statements and are not captured by the
entity's information systems relevant to financial reporting.
0 Non-compliance may involve conduct designed to conceal it, :,uch as collusion, forgery,
deliberate failure to record transactions, management override of controls or inten
tion<1l misrepresentations being made to the auditor.
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¢ Whether an act constitutes non-compliance is ultimately a matter for legal determination
by a court of law.
10. The objectives of the auditor are:
(a) To obtain sufficient appropriate audit evidence regarding compliance with the provi-
sions of those laws and regulations generally recognised tci have a direct effect on
the determination of material amounts and disclosures in the financial statements;
(b) To perform spedfied audit procedures to help identify insLancE·s of non compliance
with other laws and regulations that may have a material effect on the financial state-
ments; and
(c) To respond appropriately to non .. compliance or suspected non-compliance with laws
and regulations identified during the audit.
16. The auditor shall request management and, where appropriate, those charged with
governance to provide written representations that all known instances of non-com-
pliance or suspected non comp Hance with laws and regulations whose effects should
be considered when preparing financial statements have been disclosed to the auditor.
(Ref: Para. A12)
5.11 It may specifically be noted that SA250 clarifies that on issues relating to non compliance,
the ultimate decision would be that of a court of law. This is in sync with th~ Guidance of !CAI
which requires the auditor to have "General understanding" of various laws governing the com--
panv for amount payable under these statutes. Moreover, in the inst,rnt case it is established
beyond reasonable doubt that there was no amount r·emaining unpaid in respect of a due gov-
erned by the Service Tax Act or the GST. It needs to be noted:
l. Reversal of Input credit may not have significant impact on the financial statements,
since reversal relates to unsold inventory, the Company can upload this cost to its
Inventory. As a result, there would be no impact on statement of profit and loss, From
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121
other current assets, the amount will get reflected under Inventory, both part of cur
rent assets of the Company.
2. Materiality as at 31 March, 2018 is as under, and thus it does not even affect the un•
derstanding of the users of the financial statements (refer Balance sheets of IPL and
Victory Valley on Pages 113 to 114)

-r--·,,,,,,,
I IPL Victory Valley
!
lacs Rs lacs Rs.
/' Tota! Assets 403,585 51995
[;~~~t reversai
i
825
5.12 Accordingly, there is no question of any non reporting by the respondent in respect of the
requirements under CARO 201.6.
5.13 The allegation of the complainant regarding falsification of the financial statement and the
sc1rne not giving a true and fair state of affairs of the company is not sustainable in view of the
explanations provided above,
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5.14 Further the allegation of the complainant relating to non compliance of SAs 700/705/706 is
also baseless. !t is further submitted that the complainant has not specified which clauses or
requirements of these three SAs have not been complied with by the respondent.
5.15 Whereas the complainant has referred to SAs 700/705/706, he has not even realised that
these were Revised for appliability for financial year beginning 1st Aprii 2018. It is thus
abundantly clear that he is merely including references to these SAs without 1.mderstandine them
and without knowledge of the impact on the work of the auditor and without compret1ending
how and ln what respects they have been revised. He has not referred to any specific
requirement of the Standards which has not been complied with. In any case the complainant
cannot enhance or increase the charges hereinafter.
5.16 The allegation of the complainant that the disclosure in the accounts in respect of Ci ST and
Service Tax are a!so baseless. It is clear that the complainant did not even understand th,:Jt a
reversal of a credit would automatically mean that an amount would become payable by any
business entity to the government under the appl.icable statutes. The accounting treatment and
the disclosure issue have each been dealt with in details in the preceding paragraphs under
charge No 1.
5.17 The allegation of the complainant that non comp!iancE, of Accounting Standards for non
provision of liability and interest thereon i.s abo baseless. There was no question of non provision
of any liability and as has been explained above. Further still, the complainant has not specified
which Accounting Standard has not been complied with. In any case, preparation ot financial
statements is the responsibility ot the management and not that of an auditor. An auditor i<; only
required to comment if the financial statements are not prepared in accordance with the
applicable Accounting Standards.
5.18 With respect to the questions that have been posed by the complainant in continuity to his
so called "charges", the respondent believes that such questions can be oosed by some regulator;
under the disciplinary mechanism of ICAI, the complainant is required to make his allegations
and substantiate the same with appropriate proof/evidence. An inquiry for professionai
misconduct against J member of !CAI is governed by the provisions of tre Chartered Accountants
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Act and the Chartered Accountants (Procedure of Investigations of professional and Other
Misconduct and Conduct of Cases) Rules, 2007. The procedures established for such enquiry
does not empower to raise questions to seek information from the auditor. It has been
abundantly made dear that the complainant does not understand the process of reversal of
credit, accounting treatment at such point of time and when (and if) any iability may arise. We
have explained above1 the procedure performed in accordance with the statutory auditor and
has also provided a tabulation to demonstrate that there was no !iabilitv to be provided in the
financial statements of the companies concerned.
5.19 With respect to Charge- 4 specifica!ly, it may be noted that the Occupation Certificate for
Corridors Project was only obtained on 31st May 2019. This is a matter that rises beyond trw
financial year 2018 19. The respondi:rnt has not even submitted his aud: 1: report relating to the
financial year 2019-20. We fail to understand how the complainant can make an allegation in
this respect.
5.20 In view of the above, the respondent prays that these allegations against him sl1ould be
dropped.
6. Charge - 5
G.1 The complainant has levied this so called charge without any reference to the Clauses/Parts
to the two Schedules of the Chartered 1"\ccountants Act. This is a mandatory requirement for
every complainant, and in the absence of any specific charge for professional misconduct having
been identified by the complainant, the subsequent paragraphs deal with the factuJI issues
relating to the collection of money from Corridors ProjPcL
6.2 The allegation of the complainant is vehemently denied as the facts of the case have been
thoroughly misrepresented by him in the complaint document.
6.3 The respondent states and submits:
1. License for Corridor project was received in February, 2013 and building plan was ap
proved in July, 2013.
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2. Project was launched in 2013. Precision Realtors Private Limited was developer of the
project
3. There was change in developer from Precisions to lreo Grace Private Limited {lGR}. In flat
buyer agreement executed with the customer, IGR was disclosed as developer and Preci-
sions was mentioned as confirming party. (Copy of flat buyer agreement enclosed at
pages 115 to 122).
4. DTCP came out with a policy for change in developer on 18.02.2015. As per policy, any
change in 'beneficial interest' (BIP) of the existing developer shall make an application to
the Director General, Town and Country Planning, Haryana (DGTCP) seeking approval of
the same. (policy as per pages 80 ·- 82 of compliant)
5. As per policy, applicant seeking change in beneficial interest shall be required to deposit
administrative charges.
6. There is no provision in the policy, that developer cannot collect money from customers
without obtaining approval for change in developer.
7. DTCP vide its order dated 31.03.2016 has clarified that project i5 not In violation of Har
yana Development and Regulations of Urban Areas Act, 1975 on account of marketing
development being taken by third party other than original developer. However, it shall
be imperative to recover administrative charges where change 'n beneficial interest has
taken place without obtaining prior approval of DGTCP. (Copy of order enclosed at page
No.123)
8. The original developer, Precision Realtors Private Limited, made an application to Director
Town and Country Planning Haryana on 14.02.2019 for change of developer from Prec1
sion to lreo Grace Private Limited and Rs. 154 lakhs being 40% of administrative charges
were paid. Copy of application enclosed at page 124 to 126
9. The project has received Occupation Certificate (OC} on 31.05.2019 from Director, Town
& Country Planning Department, Haryana.
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10. If the project is in violation of DTCP, then how DTCPO has iss1;1ed occupation certificate
for the project.
11. There is no violation of 0TCP and BIP rules.
12. At the time of launch of BIP policy on 18.02.2015, complainant was group CFO of treo
6.4 As part of the audit procedures performed, the respondent had:
1. Studied DTCP policy dated 18.02.205 regarding change in developer. As per policy, for
any change in 'beneficial interest' (BlP), existing developer shall make an application to
the Director General, Town and Country Planning, Haryana {DGTCP) seeking approval of
the same.
2. Obtained copy of DTCP order dated 31.03.2016, where it has been clarified that project
is not in violation of Haryana Development and Regulations of Urban Areas Act, 1975 on
account of marketing or development being taken by third party other than original de-
veloper. However, it shall be imperative to recover administrative charges where change
in beneficial interest has taken place without obtaining prior approvai of DCi IC.P.
3. Obtained copy of application made by lreo Group to Director Town and Country Planning
Haryana on 14.02.2019 for change of developer from Precision to lreo Grace Private Lim-
ited and verified payment of administrative charges.
6.5 The complainant has referred to SA 250 and SA240. Before dealing with the relevant parts ot
these two Standards it is important to list some of the vital principles as establishPd under SA200
which basically serves as a backdrop for all audit engagements:.
SA 200
4_ The financial statements subject to audit are those of the entity, prepared and presented
by management of the entity with oversight from those charged with governance. SAs do
not impose responsibilities on management or those charged with govermmce and do not
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override laws and regulations that govern their responsibilities. However, an audit in oc
cordance with SAs is conducted on the premise that management and, where appropri-
ate, those charged with governance have responsibilities that are fundamental to the con-
duct of the audit. The audit of the financial statements does not relieve management or
those charged with governance of those responsibilities. {Ref: Para. A2-A11)
5. As the basis for the auditor's opinion, SAs require the auditor to obtain reasonable assur•
ance about whether the financial statements as a whole are free from material misstate-
ment, whether due to fraud or error. Reasonable assurance is a high level of assurance. it
is obtained when the auditor has obtained sufficient appropriate audit evidence to reduce
audit risk (i.e., the risk that the auditor expresses an inappropriate opinion when the fi••·
nancial statements are materially misstatt~d) to an acceptably low !eveL However, rea-
sonable assurance is not an absolute level of assurance, because there are inherent !im1
tations of an audit which result in most of the audit evidence on which the auditor draws
conclusions and bases the auditor's opinion being persuasive rather than conclusive. {Ref:
Para. A28··A53)
Overall Objectives of the Auditor
11. In conducting an audit of financial statements, the overaH obJectives of the auditor
are:
{a) To obtain reasonable assurance about whether the financial statements as
a whole are free from material misstatement, whether due to fraud or er-
ror, thereby enabling the auditor to express an opinion on whether the

financial statements are preparE•d, in all material respects, in accordance
with an applicable financial reporting framework; and
(b} To report on the financial statements, and communicate as required by the
SAs, in accordance with the auditor's findings.
12. In a!! cases when reasonable assurance cannot be obtained and a qualified
opinion in the auditor's report is insufficient in the circumstances for purposes of
..J....j,
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reporting to the intended users of the financial statements, the S.A.s require that
the auditor disdaim an opinion or withdraw from the engagement, where with
drawal is legally permitted.
13 {k) Professional judgment - The application of relevant training, knowledge and experi-
ence, wlthin the context provided by auditing, accounting and ethical standards, in
making informed decisions about the courses of action that are appropriate in the cir-
cumstances of the audit engagement.
(!) Professional skepticism -An attitude that includes a questioning mind, being alert
to conditions which may indicate possible misstatement due to error or fraud, and
a critical assessment of audit evidence.
(rn) Reasonable assurance - In the context of an audit offinancial statements, a high,
but not absolute, level of assurance.
The Auditor's Responsibilities in Relation to the Financial Statement Audit
18. The auditor shall communicate with those charged with go·Jernance the responsibili-
ties of the auditor in relation to the financial statement audit, in duding that:
(a) The auditor is responsible for forming and expressing an opinion on the financial
statements that have been prepared by managernent with the oversight of those
charged with governance; and
(b) The audit of the fim1ncial statements does not relieve management or those
charged with governance of their responsibilities. (Ref: Para. A9·~A10)
A18. Professional skepticism includes being alert to, for example:
· Audit evidence that contradicts other audit evidence obtained.
· Information that brings into question the reliability of documents and
responses to inquides to be used as audit evidence.
· Conditions that may indicate possible fraud.
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• Circumstances that suggest the need for audit procedures in addition to those
required by the SAs.
A23. Professional judgment is essential to the proper conduct of an audit. This is because
interpretation of relevant ethical requirements and the S/\s <1nd the informed deci·
sions required throughout the audit cannot be made without the application of rel
evant knowledge and experience to the facts and circumstances. Professional judg
ment is necessary in particular regarding decisions about'
· Materiality and audit risk.
· The nature, timing, and extent of audit procedures used to meet the
requirements of the SAs and gather audit evidence.
· Evaluating whether sufficient appropriate audit evidence has been obtained, and
whether more needs to be done to achieve the objectives of the SAs and thereby,
the overall objectives of the auditor.
· The evaluation of management's judgments in applying the entity's applicable fi
nancia! reporting framework.
· The drawing of conclusions based on the audit evidence obtained, for example,
assessing the reasonableness of the estimates made by management in preprmng

the financial statements.
A24. The distinguishing feature of the professional judgment expected of an auditor is
that it is exercised by an auditor whose training, knowledge and experience huve
assisted in devetoping the necessary competencies to achieve reasonable judg

rnents.
A25. The exercise of professional judgment in any particul.,r case is based on the facts
and circumstances that ;:,re known by the auditor. Consultation on difficult or con
tentious matters during the course of the audit, both within the engagement tearn
and between the engagement team and others at the appropriate !eve! within or
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outside the firm, such as that required by SA 22016, assist the auditor in making
informed and reasonable judgments.
A26. Professional judgment can be evaluated based on whether the judgment reached
reflects a competent application of auditing and accounting principles and is appro
priate in the light of, and consistent with, the facts and :::ircumstances that were
known to the auditor up to the date of the auditor's report.
A27. Professional Judgment needs to be exercised throughout the audit. lt also needs to
be appropriately documented. In this regard, the auditor is required to prepare au
dit documentation sufficient to enable an experienced auditor, having no previous
connection with the audit, to understand the significant professional judgments
made in reaching conclusions on significant matters arising during the audit . Pro
tessional judgment is not to be used as the justification for decisions that are not
otherwise supported by the facts and circumstances of the engagement or sufficient
appropriate audit evidence.
A32 Audit risk is a function of the risks of material misstatement and detection risk. The
assessment of r1sks is b:ised on Rudit procedures to obtarn information necessorv
for that purpose and evidence obtained throughout the audit. The assessment of
risks is a matter ot professional judgment, rather than a rnatter capable of precise

measurement.
A47. There are practical and legal iimitations on the auditor's ability to obtain audit evi-
dence. For example:
· Th,;,re i\ the possibility that management or others may not provide, intentionally
or unintentionally, the complete information that is relevant to the preparation

and presentation of the financial statements or that has been requested by the
auditor. Accordingly, the auditor cannot be certain of U·e completeness of infor
mation, even though the auditor has performed audit procedures to obtain assur
ance that all relevant information has been obtained.
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Fraud may involve sophisticated and carefully organised schemes designed to con-
ceal it. Therefore, audit procedures used to gather audit evidence may be ineffec
tive for detecting an intentional misstatement that involves, tor example, co!lu
sion to falsify documentation which may cause the auditor to believe that audit
evidence is valid when it is not. The auditor is neither trained as nor expected to
be an expert in the authentication of documents.
· An audit is not ~in official investigation into alleged wrongdoing. Accordingly, the
auditor is not given specific legal powers, such as the power of search, which may
be necessary for such an investigation.
6.6 Further the performance of the audit is linked to the verification procedures and the docu
mentation of each auditor which are dealt with in SA230 as follows;
SA 230
5. The objective of the auditor is to prepare documentation that provides:
(a) A sufficient and appropriate record of the basis for the auditor's report; and
(b) Evidence that the audit was planned and performed in accordance with SAs and
applicable legal and regulatory requirements.
6. 7 Accordingly, an auditor is required to perform his procedures in compliance with the Stand-
cnds, but the contents of the Standards also describe in details the practical issue::. ,rnd the lirni
tations to the obligations and responsibilities of the auditor. The work performed by the auditor
is largely required to be documented and his conclusions should be based on the procedures
performed, documentation examined, discussions with the management and their representa-
tions and his own skills that include professional skepticism. ln each cf the cases, the respondent
had performed his duties and arrived at his conclusions in a must anc, appropriate manner, Once
an audftor can explain his work flow and his working files support his assertions, and the proce-
dures are in accordance with the requirements there can be no question of gross negligence.
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6.8 Based on the facts of the matter and the audit procedures performed, it is evident that there
was no question of any fraud with respect to the issues listed by the complainant in his so called
Charge - 5.
6.9 The undersigned however was fully aware of his obligations under SA240 morP specifically
with respect to the following:
SA 240
Responsibility for the Prevention and Detection of Fraud
4, The primary responsibility for the prevention and detection of fraud rests with both those
charged with governance of the entity and management. It is important that manage
ment, with the oversight of those charged with governance, pl.1ce a strong emphasis on
fraud prevention, which may reduce opportunities for fraud to take place, and fraud de-
terrence, which could persuade individuals not to commit fraud because of the likelihood
of detection and punishment. This involves a commitment to creating a culture of honesty
and ethical behavior which can be reinforced by an active oversight by those charged with
governance. !n exercising oversight responsibititv, those charged with governance con
sider the potential for override of controls or other inappropriate influence over the fi.
nancial reporting process, such as efforts by management to manage earnings in order to
inrluence the perceptions of analysts as to the entity's performance and profitability.
Responsibilities of the Auditor
5. An auditor conducting an audit in accordance with SAs is responsible for obtaining rea
sonable assurance that the financial statements taken as a whole are free from materia!
misstatement, whether caused by fraud or error. Owing to the inherent !imitations of an
audit, there is an unavoidable risk that some material misstatements of the financial
statements may not be detected, even though the audit is properly planned and per
formed in accordance with the SAs.1
6, As described in SA 200, the potential effects of inherent limitations are particularly signif-
icant in the case of misstatement resulting from fraud. The risk of not detecting a material
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misstatement resulting from fraud is higher than the risk of not detecting one resulting
from error. This is because fraud may involve sophisticated ;ind carefully organized
schemes designed to conceal it 1 such as forgery, deliberate failure to record transactions,
or intentional misrepresentations being made to the auditor. Such attempts at conceal-
ment may be even more difficult to detect when accompanied by collusion. Collusion rnay
cause the auditor to believe that audit evidence is persuasive when it is, in fact, false, The
auditor's ability to detect a fraud depends on factors such as the ::.kiHfulness of the per-
petrator, the frequency and extent of manipulation, the degree '.Jf collusion involved, the
relative size of individual amounts manipulated, and the seniority of those individuals m
valved. While the auditor may be able to identify potential opportunities for fraud to be
perpetrated, it is difficult for the auditor to determine whether misstatements in judg-
ment areas such as accounting estimates are caused by fraud or error.
7. Furthermore, the risk of the auditor not detecting a material mhstatement resulting from
management fraud is greater than for employee fraud, because management is fre-
quently in a position to directly or indirectly manipulate accounting records, present
fraudulent financial information or override control procedures designed to prevent sim-
ilar frauds by other employees.
8. When obtaining reasonable assurance, the auditor is responsible ~or maintaining profes-
sional skepticism throughout the audit, considering the potential for rnanagernent over-
ride of controls and recognizing thP fact that audit procedurE'.:, that are effective tor de
tecting error may not be effective in detecting fraud. The requirements in this SA are de-
signed to assist the auditor in identifying and assessing the risk; of material misstatement
due to fraud and in designing procedures to detect such misstatement.
13, Unless the auditor has reason to believe thE, contrary, the audi1:or may accept records and
documents as genuine. If conditions identified during the aucit cause the auditor to be
!ieve that a document may not be authentic or that terms in a document have been mod"
ified but not disclosed to the auditor, the auditor shall investigate further.
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39. The auditor shall obtain written representations from management and, where applica-
ble, those charged with governance that:
(<l) They acknowledge their responsibility for the design, implementation and mainte-
nance of internal control to prevent and detect fraud;
(b) They have disclosed to the auditor the results of management's assessment of the
risk that the financial statements rr1ay be materially misstated as a result of fraud;
(c) They have disclosed to the auditor their knowledge of fraud or suspected fraud
affecting the entity involving:
(i) Management:
(!!} Employees who have significant roles in internal control; or
{iii} Others where the fraud could have a material effect on the financial state-
ments; and
(d) They have disclosed to the auditor their knowledge of any allegations of fraud, or
suspected fraud, affecting the entity's financial statements communicated by em
ployees, former employees, analysts, regulators or others. (Ref: Pt1rJ. /\57A58)
6.10 As far as compliance with SA250 is concerned the respondent reiterates that he had dis-
charged his duties in accordance with the prescribed requirements as below:
SA 250
5. The auditor is responsible for obtaining reasonable assurance that the financial
statements, taken as a whole, are free from materia misstatement, whether
caused by fraud or error. In conducting an audit of financial statements, the audi-
tor takes into account the applicable legal and regulatory framework. Owing to
the inherent limitations of an audit, there is an unavoidable risk that some mate
rial misstalemenls in the financial statements may not be detected, even though
the audit is properly planned and performed in accord;rnce with the SAs In the
context of laws and regulations, the potential effects of inherent limitations on
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the auditor's ability to detect material misstatements are greater for such reasons
as the following:
There are many laws and regulations, relating principally to the operating
aspects of an entity that typically do not affect t·1e financial statements
and arc not captured by the entity's information systems relevant to fin an
cia! reporting.
i'fon .. compliance may involve conduct designed tc conceal it, such as col
lusion, forgery, dehberate failure to record transactions, management
override of controls or intentional misrepresentations being made to the
auditor.
Whether an act constitutes non•comp!lance is ultimately a matter for legal
determination by a court of law.
10. The objectives of the auditor are:
(a) To obtain sufficient appropriate audit evidence regarding compliance with the
provisions of those laws and regulations generally recogrised to have a direct ef-
fect on the determination ot material amounts and disclosures in the financial

statements;
(b) To perform specified audit procedures to help identify instances of non- compli•
a nee with other laws and regulations that may have a material effect on the finan-
cial statements; and
(c) To respond appropriatelv to non-compliance or suspectr:~d non-compliance with

laws and regulations identified dunng the audit.
16. The auditor shall request management and, where appropriate, those charged w:th
governance to provide written representations that all known instances of non-com-
pliance or suspected non-compliance with laws and regulations whose effects should
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be considered when preparing financial statements have been disclosed to the audi·
tor. (Ref: Para. A12}
11. Before we conclude, it is important to recapitulate that:
l. The pro3ect was launched in 2013, before PIL policy released on 18.02.2015.
2. DTCP vide its order dated 31.03.2016 has clarified that pro;ect is not in v1olat1on
of Haryana Development and Regulations of Urban Areas A.ct, 1975 on account of
marketing development being taken by third party other than original developer.
However, it shall be imperative to recover administrative charges where change in
beneficial interest has taken place without obtaining pr'iol' approval ot DGTCP.
{Copy of order endosed)
3. Revised building plan was approved by DTCP, Haryana on 10.07.2017
4. The original developer, Precision Realtors Private Urnitecl, made an application to
Director Town and Country Planning Haryana on 14.02.2019 for change of devel
oper from Precision to lreo Grace Private Limited and Rs 1S4 lakhs being 40% of
administrative charges were paid,
5. In flat buyer agreement executed with the customer, lreo Grace was disclosed as
developer and Precisions was mentioned as confirming party. That was before PIP
policy was introduced.
6. We, as auditor have verified Bl P policy, DTCP Order dated 31.03.2016 and applied
tion filed by the companv for change of developer.
7. Documents listed at page 77 to 84 of the compliant are lette,s trom DTCP Haryana
Lu D,!lhi ruiice. These are not in public domdin. We c,:irrnul rnJ!<c Jny cunirnc,1L
on this. We do not know, how these letters came in possession of the complainant
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6.12 The complainant has further referred to Section 143(:12} of the Companies Act 2013. The
statute includes the following requirements:
"Sub-section 12 of Section 143 of the Compan1es Act, 2013 ("the 2013 Act" or "the Act"}, as
amended, states, "Notwithstanding anything contained in this section, if an auditor of a com--
pany, in the course of the performance of his duties as auditor, has reason to tJeiiPve that an
offence of fraud involving such amount or amounts as may be prescribed, is being or has been
comm1tted in the company by its officers or employees, the auditor shall report the matter
to the Central Government within such time and in such manner as may be prescribed:
Provided that in case of fraud involving lesser than the specified arr,ount, the auditor shall
report the matter to the audit committee constituted under section 177 or to the Board in
other cases within such time and in such manner as may be prescribed:
Provided further that the companies, whose auditors have reported frauds under this sub
section to the audit committee or the Board but not reported to the Central Government,
shall disclose the details about such frauds in the Board's report in such manner ,3s may be
prescribed."
G. B Further the Guidance Note issued by !CA! on Section 143(12) of the Comp:m1es Act 2013
includes the foHowing comments:
'·):. Should the Auditor Report under Section 143(12) in case of Cor·uption, Bribery, Money
Laundering and Non.. compliance with other Laws and Regulations.
In case of corruption, bribery and money laundering, the direct effect of such act I benefit or
pt::,nal consequence) is on the cornp,my.
The auditor should comply with the relevant SAs with regard to illegal acts (e.g. SA 2.40 and
SA 250, "Consideration of Laws and Regulations in an Audit of Financial Statements") when
performing the audit. If the auditor, in the course of performance of his/her duties as the
auditor, corr1es across instances of corruption, bribery and money laundering and other in
tentional non,comp!iances with laws and regulations, the auditor would need to evaluate the
impact of the same in accordance with SA 250 to determine whether the same wculd have a
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material effect on the financial statements.
With respect to reporting under Section 143(12), consequent to corruption, bribery, money
laundering and other intentional non-compliance with other laws 2ind regulations, the audi-
tor should consider whether such acts have been carried out by officers or employees of the
company for the purpose of reporting and also take into account the requirements of SA 250,
particularly paragraph 28 of SA 250 read with paragraphs A19 and /~20."
6.14 The relevant paras of S250 referred in the Guidance Note are as follows:
"SA 250
Reporting Non-Compliance to Regulatory and Enforcement Authorities
28. If the auditor has identified or suspects non-compliance with laws and regulations,
the auditor shall determine whether the auditor has a responsibility to report the
identified or suspected non-compliance to parties outside the entity (Ref: Para.
A19A20)
.1~ 19. The auditor's professional duty to maintain the confidentiality of client information
m;:iy preclude reporting identified or suspected non•compliance with iaws and reg
u!ations to a party outside the entity. However, the audi·:or's legal responsibilities
vary under different laws and regulations and, in certain circumstances. thp duty
of confidentiality may be overridden by statute, the law or courts of law. Under
the present legal and regulatory framework for finandal instit1.;t1ons 1n India, their
auditor has a statutory duty to report the occurrence, or 'iuspected occurrence, of
non-compliance with laws and regulations to supervisory authorities. For exarnplp,
the auditor is required to report certain matters of non-c,::impliance to the Reserve
Bank of India as per the requirements of Non Banking Financial Companies Audi
tor's Report (Reserve Bank) Directions, 1988, issued by t1e Reserve Bank of lnd1ri.
Also, some laws or regulations require the auditor to report misstatements to au-
thorities in those cases where management and, where applicable, those charged
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with governance fai! to take corrective action. The auditor may consider it appro-
priate to obtain legal advice to determine the appropriate course of action.
A2O. In case of certain entities, such as national governments, regional (for example,
state, provincial, territorial) governments, local (for example, city, town) govern-
ments and related governmental entities (for example, ag1~ncies, boards, com mis
sions and enterprises), the auditor may be obliged to report on instances of non
compliance to governing authorities or to report them in the auditor's report."
6.15 There was no question, in view of the requirements of Section 143:12) of the Companies
Act and the guideHnes issued by ICAI to report any fraud. The complainant has not even stated
how he believed any reporting under Section 143(12) of the Companies A,:t was warranted.
6.16 The respondent has thus already provided the factual details and the audit procedures per•
formed with complete knowledge and understanding of the relevant SA, there was no such in·
stance which required reporting of a fraud under Section 143(12) ot the Companies Act, 2013.
6.17 In vilcJW of the above the respondent prays that this charge be droppi,:d.
7. Charge-6
7.1. The allegation in the so called Charge No: 6 is vehemently denied.
7.2 The complainant has again referred to SA 240 and SA 250 and Section 143(12) of the
Companies Act, 2013.
7.3 We are not reproducing the relevant parts of the two SAS and the contents of Section 143(12)
of the Companies Act, 2013. Reference may be made to the detailed discussions contained with
respect to our response to so called Charge No: 5 referred above.
7.4 It may specifically be stated that:
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1. One company provides services to the company of lreo Group relat;ng to renting of office
space, manpower, accounting, and administrative services. The Company raises invoice
on other Company and Service Tax/ GST is charged on invoices
2. Sample of invoices selected for testing for financial year 2017-18 and 2018 .. 19 are en-
closed at pages 127 to 146
7.5 Further, the respondent had performed the following audit procedures:
l. Selected samples for testing
2. Obtained copies of Invoices raised on Inter-company for charge of common facilities
and/or cost sharing.
3. Verified basis of calculation of amounts
4. Verified that Service Tax/ GSR, if applicable is charged
S. Verified that invoices are duly approved
6. Traced invoices to ledger account
7.6 Further still the complainant is referring to 20 companies while explaining the so called
Charge No: 6, whereas the respondent is not the auditor for 20 companies.
7.7 The complainant has referred to Pages 8~ to 97 of the complaint dccument with an intent to
rnislead ICAI since the financial statements could naturally not show t!w ;;ccotmting treatment in
respect of inter.. company invoices. The respondent reiterates that th•:' inter-company invoices
inducted the element of Service Tax/GST as applicable.
7.8 In view of the above the respondent prays that this charge be dropped.
8. Charge- 7
8.1 The allegation in the so called Charge No: 7 is vehemently denied.
8.2 The complainant has again referred to SA 240 and SA 250 and Section 143(12) of the
Companies Act, 2013.
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8.3 V\le are not reproducing the relevant parts of the two SAs and the contents of Section 143( 12)
of the Companies Act., 2013. Reference rr1ay be made to the detailed discussions contained wirh
respect to our response to so called Charge No: 5 referred above.
8.4 It may specifically be stated that:
1. As per CENVAT rules, in case vendor invoice is not paid with in 90 days of date of invoice,
input credit has to be reversed. Subsequently, when such payment of vendor is made,
such input can be re-credited. There is no time limit for re-credit
2. There are similar provision in GST. Where payment is not made to the supplier of goods
or services with in 180 days of invoice date, input credit has to be r,eversed Recipient of
goods and services will be entitled to avail of the credit of input tax on payments made
by him to vendor.
3. The Company has a procedure, that whenever there is delay in ~)ayment to vendors be-
yond 180 days, input credit is parked in a separate account, Sample of Ledger account of
the same is enclosed at Page Nos. 147 to 149
11 .t\s per Service Tax/ GST r~1!es, there i'.; deferment of input credit. Th(? Company is entit!ed
for the input credit once payment is made to vendor. There is no time limit prescribed for
such re-credit.
5, There is no impact on the financials since the Company has right for input credit.
6. The Gooch anc.'
PdVntt:·nts of NOU be only on the net cash tax ii;ibdity after d,·cLx
tion of avaHab1e f!11s change win apply on a

from
8.5 As part of the audit procedures performed., the respondent had ensured the following:
1. Took understanding of Service Tax/ GST rules. in case of non payment to vendors
within 90 days/ 180 days under Service Tax/ GST, input credit availed on purchase of
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goods and services has to be reversed. Recipient of goods and services will be entitled
to avail of the credit of input tax on payments made by him to vendor.
2. Obtain an understanding of Company's accounting system regarding reversal of input
credlt.
3. As per system in place, input credit on unpaid bills beyond 90 days / 180 days are
parked in a separate account.
4. Verified ledger accounts for GST Inputs in respect of unpaid bills beyond 90 days/ 180
days
5. Test samples for operating effectiveness
8.6 Whereas the respondent has performed his verification procedures to satisfy himself, the
complainant has merely provided copies of some documents relating to some list of transactions
8.7 With reference to documents attached at page 98 to 102 of the co·np!amt, it has been clan
fied that there is no time limit for re credit ot input credit Le the Company can claim input cred,t
whenever payment is made to vendor beyond 90/180 days. The Company is entitled for Input
credit, although utilisation is deferred. Li,ibiHty for vendor payments has already been accountec1
at full value including service tax/GST.
9. Charge-8
9.1 The allegation in the so caHed Charge No; 8 is vehemently denied.
9.2 The respondent states a5 follow·s:
L As per clause {vii) of CARO, auditor has to report the statutory dues which are outstanding
for more than 6 months as at balance sheet date.
2. As at 31 March, 2018 - There was no amount of TDS, which was outstanding for more
than six months as at 31 March, 2018.
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3. As at 31 March, 2019, in two companies, TDS was outstanding for more than 6 months
and these outstanding amounts were reported in CARO (Copies of auclit reports enclosed,
refer Page Nos Clause (vii) of Page 155 of 150to 157 for IPL and dause {vii) of page 162
of pages 158 to 163 for lreo Victory Valley
Amount (Lacs Rs.)
j 703.20
l
April to September, 201.8 775.13
lreo Victory Valley April 2018 28.37
May to September, 2018 104.81
4. Income Tax department had sent letters to banks on 25 March, 2019 for freezing of ac.
counts and these accounts were de-freeze vide Asst Commissioner letter dated 7.05.2019
5. t\S per Schedule lll to the Companies Actt 2013, Cash Jnd cash 2qt. ivalents sh2!! Je class:~
fied as:
a. Balances with Banks (of the nature of cash and cash equivalents);
b. Cheques, drafts on hand;
c. Cash on hand; and
d. Others (specify nature).
The following disclosures with regard to cash and bank balances shall be made:
(a) Earmarked balances with banks (for example. for unpaid dividend) shall be
separately stated.
(b) Balances with banks to the extent held as margin money or security against the
borrowings, guarantees, other commitments shall be disclosed separately.
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(c) Repatriation restrictions, if any, in respect of cash and bank balances shall be sep-
arately stated.
6. There was temporary freeze of bank accounts and in our opinio1, no disclosure is required
as per Schedule m to the Companies Act, 2013
9.3 As part of the audit procedures performed, the respondent had studied the following:
Reporting of TDS outstanding for more than 6 months
As required by Clause (vii) of CARO, auditor has to report: 'Whether the company is reg
ular in depositing undisputed statutory dues induding Provident Fund, employees 'State
lnsu ranee, Income-tax, Sales-tax, Service Tax, duty of customs, duty of excise, value added
tax, cess and any other statutory dues to the appropriate authoriti,:>s and if not, the extent
of the arrears of outstanding statutory dues as on the last day of the financial year con
cerned for a period of more than six months from the date thev became payable, shall bE0
indicated'
Auditor is also required to state the extent of arrears of statutory dues which have re
mai ned outstanding as at the last day of the financial year concerned for a period of more
than six months from the date, they became due.
9.4 For the purpose of CARO reporting, regarding defaults in payment of TDS, we performed fol.
lowing procedures:
1. Obtained an understanding of the provisions of TDS and dues dates for deposit of TDS.
2. Obtained ledger dump of TDS payable accounts
3. TDS payments were identified from the ledgers and payments were traced with challans
of deposit
4. Summary of balances as per TDS return and books of account was prepared
5. Summary of year-end liability was prepared, and subsequent payments were verified
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6. Mont-wise summary of TDS deducted and deposited was prepared. (Copy of workpaper
enclosed at Pages 164 to 167
7. Closing liability as at balance sheet date was traced to the month of deduction and its due
date. Amount outstanding for more than 6 months was identified for reporting in CARO
8. Arrears of TDS which were outstanding for more than 6 months were reported in CARO
in accordance with the guidance note issued by !CAI
9.5 In respect of Freezing of Bank Accounts, the Income Tax department had sent letters ta banks
on 25 March, 2019 for freezing of accounts and these accounts were dE'-freezed vide Asst Com-
missioner letter dated 7.05.2019. (copy of one sample letter attached at Page 168) There is no
reporting requirement as per CARO 2016 or Schedule Ill to the Comp,rnies t:\ct, 2013, Even in
CARO 2020, no such provision has been incorporated,
9.6 The respondent harl thus ensured that appropriate compliance with disclosures and reporting
under the law had taken place,
9, 7 The respondent prays that this allegation be dropped.
10, Charge - 9
10.l The allegation in the so called Charge No: 9 is vehemently denied.
10,2 The complainant has referred to SA 315 and SA580 in the so called Charge No: 9.
10.3 While referring to SA315, the complainant ftra'., staled that the auditor "was bound to see
the integrity of the management'', and he has stated that it is a specific requirement of Si\315.
10.4 SA315 specifically includes the following:
Objective
3. The objective of the auditor is to identify and assess the risks of material misstatement
vvhether due to fraud or error., at the financial statement and assertion levels, through un
derstanding the entity and its environment, including the entity's intNnal controi, thereby
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providing a basis for designing and implementing responses to the assessed risks of material
(i) its operations; misstatement. This will help the auditor to reduce the risk of material mis-
statement to an acceptably low level.
6. The risk assessment procedures shall include the following:

{a) Inquiries of management, of appropriate individuals within the internal audit function (if
the function exists), and of others within the entity who in the auditor's judgment may have
information that is likely to assist in identifying risks of material misstatement dLH~ to fraud
or error. (Ref: Para. A6 A12)
(b) Analytical procedures. (Ref: Para A13-A16)
(c} Observation and inspection. (Ref: Para. Al7}
The Entity and Its Environment
11. The auditor shall obtain an understanding of the following:

(a) Relevant industry, regulatory, and other external factors includi'lg the applicable financial
reporting framework. (Ref: Para . .l\23 A28)
(bl The nature of the entity, including:
{ii) its ownership and governance structures;
(iii} the types of investments that the entity is making and plans to mai{e, including invest
ments in special-purpose entities; and
(iv} the way that the entity is structured and how it is fin,.:mced;
to enable the auditor to understand the classes or transactions, account balances, and dis
closures to be expected in thB financial statements. (Ref: Para. A29 A33)
(cl The entity's selection and application of accounting policies. including the reasons for
changes thereto. The auditor shall evaluate whether the entity's accounting policies are ap-
proprtate for its business and consistent with the applicable financial reporting framework
and accounting policies used in the relevant industry. (Ref: Para. A34)
{d) The entity's objectives and strategies, and those related busine:is risks that may result in
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risks of material misstatement. (Ref: Para. A35-A4l}
(e) The measurement and review of the entity's financial performance. (Ref: Para. A42 A47)
25. The auditor shall identify and assess the risks of materia! misstatement at
(a) the financial statement !c::vel; and (Ref: Para. A117-A120}
(b) the assertion level for classes of transactions, account balances, and disclosures; (Ref:
Para. Al21-A125)
to provide a basis for designing and performing further audit procedurns.
26. For this purpose, the auditor shall:
(a) Identify risks throughout the process of obtaining an understand,ng of the entity and its
environment, including relevant controls that relate to the risks, and bv considedng the clas
ses of transactions, account balances, and dlsclosures in the financial statements; (Ref: Para.
Al26-;.\127)
(b) Assess the identified nsks, and evaluate whether they relate more pervasively to the fi-
nancial statements as a 1,vhole and potentially affect many assertions;
(c) Relate the id(~ntified risks to what can go wrong at the assertion !evel, taking account of
reievant contcub UiciL tht:: ,rndirnr intends to tesL; and (Ref: Para. A128-i\130)
(d) Consider the likelihood of n,1sstaten1ent, mcluding the possibility of multiple misstate-
ments, and whether the potential misstatement is of a magnitude that could result in a ma-
terial misstatement.
10.5 The complainant has rnischievously referred to this Standard without identifying any partic·
ular paragraph. It is however a fact that every auditor would form a general view regarding thP
approach and outlook of the management and those charged with gow,rnance before relying on
their d~~ertions. However, the work of the auditor with respect to SA 315 has a different
approach.
10.6 As part of the audit procedures perforn,ed the undersigned had ensured:
1. We have verified consent given by the directors in Form DIR -2 ·:hat they are not disqual
ified to become a director under the Companies Act, 2013
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2. We have verified the provisions of the Companies Act to check, whether there are anv
reporting requirements by auditors in cvse any of the director is dedared as proclaimed
offender.
3. As per the provisions of Section 167(1) (f} of the Companies Act, 2013, a director vacates
the office of director if 'he is convicted by a court of any offenc.'.:!, whether involving moral
turpitude or otherwise and sentenced in respect thereof to mprisonment for not less
than six months'. We enquired from the Company, whether any such order has been
passed against any of the director of the Company. We also use goog!e alert to keep us
informed of such cases.
10. 7 As far as SAS80 is concerned the following paragraphs are relevant:
SA 580
15. If the auditor has concerns about the competence, integrity, ethical values or dili
gence of management, or about its commitment to or enforcement of these. the
auditor shall determine the effect that such concerns may have on the reliabil
of representations {oral or written} and audit evidence i.1 general. (Ref: Para. /\24
AZS)
16. In particular, if written representations are inconsistent with other audit ev 1
dence, the auditor shall pertorm audit procedures to attempt to resolve the mat
ter. ff the matter remains unresolved, the auditor shall r "~consider the assessn1ent
1
of the competence, integrity, ethical values or diligence of management, or cf its
commitment to or enforcement of these, and shall determine the effect that this
may have on the reliability of representations (oral or written) and audit evidence
in general.
A23. fn the case of identified inconsistencies between one or rnore written representzi
tions obtained from another source, the auditor may consider whether the nsk
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assessment remains appropriate and, if not, revise the risk assessment and deter-
mine the nature, timing and extent of further audit procedures to respond to the
assessed risks.
A25. SA2308 requires the auditor to document significant matt1;,rs arising during the
audit, the conclusions reached thereon, and significant professional judgments
made in reaching those conclusions. The auditor may have identified significant
issues relating to the competence, integrity, ethical values or diligence of manage ..
ment, or about its commitment to or enforcement of thes<~, but concluded that
the written representations are nevertheless reliable. In such a case, this signifi
cant matter is documented in accordance with SA 230.
10.8 There was no reason for the respondent not to rely on the management repn:sentation;
there was no conflict of any nature between the various representations of the management,
and between vvhatever evidence was available during the performance of the audit procedures.
10.9 It is an acceptable part of !aw in the country that no individual is deemed to be guilty untr!
he 1s actually found guilty by the Court of Law. Once the person is pronounced guilty by the
courts, the concerned provisions of the Companies Act, 2013 would become operative.
10.10 The complainant has blatantly tried to paint the responsibility of the auditor much bevoncl
and different from what the law provides. Disclosures that are not required under the statutes
cannot be made the basis of any allegation for professional misconduct. Neither is the auditor
required to be informing any police station about any Director of the company who may be facing
action by the authorities.
10 11 The respondent thus prays that this allegation be dropped.
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11. Charge - 10
11.1 The allegation in the so cailed Charge No: 10 is vehemently denied.
11.2 The complainant referred to SA250 and SA240 and Section 143(12) of the Companies /\ct,
2013. Our comments in respect of the relevant parts of these Standards and Section 143(12)
have been dealt with at length by the respondent in Charge No: 5 above. For reasons of brevity,
they are not reproduced here again, and the same may be deemed t:) be included herein. It is
further submitted that any allegation for professional misconduct is required to be specific and
pin-pointed. The complainant merely referring to the Standards without identifying the specific
requirement. This cannot constitute an allegation under any circumstances.
1 L3 It is further submitted that:
1. As per sale deed dated 24 August 2010, purchaser is mentioned as 'Mf',, Global Estate·, c1
Company registered under the provisions of the Companies Act 1 1956.
2. Precious Realtors Private limited, Maderia Conbuild Private Limited, Blue Planet Infra de-
velopers Prlvate limited and Global Estate entered into a Memorandum of Understanding
(MOU) on 27.08.2010 for filing an application for grant or group housing colony licence
for its land area in village Dhumaspur and Maidawas, Distt Gurgaon. As explained to u'I
name was inadvertently mentioned as Global Estate Private Limited
3. By addendum dated 8.6.2011, to MOU dated 27.08.2010, was executed to amend name
of Global Estate as partnership firm. (attached at Page No..s 169-178) Rectificat1on
deed was executed as registered on 18.02.2013, where it was rectified that Global Estate
is a partnership firm.
4. As explained to us, all these amendments and rectifications are placed in the records of
DGTCP.
5. As explained to us, in sale deed name of Global Estate, partnership firm was inadvertently
mentioned as Global Estate Private limited.
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6. Reply of the Company to EOW Mandlr Marg is attached at page No. 179 to 180. (an
nexures are not enclosed being too voluminous}
11.4 As part of the audit procedures performed the undersigned had ensured the following:
1. For the purpose of verification of land included under Inventory, we had verified !,ind
purchase from Registered sale deeds/ development agreements.
2. In sale deed land is registered in the name of 'Global Estate Private Limited' instead of
Global Estate, a partnership firm.
3. We made enquiries to the Company, for difference in name.
4. It was explained to us that, in sale deed name of Global Estate, partnership firm was in
advertently mentioned as Global Estate Private Limited.
5. We verified addendum dated 8.6.2011, to MOU date 27.08.2010, was executed to amend
name of Global Estate as partnership firm. Rectification deed was executed and registered
on 18.02.2013, where it was rectified that Global Estate is a partnership firm. (Rectifica
tion deed attached at pages 181 to 187)
6. As explained to us, all these amendments and rectifications are placed in the records ot
DGTCP.
11.5 It needs to be specifically noted:
1. As explained to us, in sale deed name of Global Estate, partnership firm was inadvertently
mentioned as Global Estate Private Limited.
2. As per pages 117 and 118 of the complaint, the Company has in'ormed to ThE• Director
General Town and Country Planning, Haryana in 2013, that Global Estate was inadvert
ently mentioned as Global Estate, a Company incorporated under the Companies Act This
typographical and clerical error has been rectified be executing rectification deed.
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11.6 It may further be stated that the transaction of purchase of land referred in this allegation
did not take place during the year when the respondent was the auditor of any of the companies
of IRE0, and further that the respondent has never been the auditor ::>l Global Estates.
11. 7 The respondent thus prays that this allegation be dropped.
12. Charge -11
12.2 The respondent states as follows:
1. As alleged, payment was made by Precision ....... on 19.l.2015
2. We have not audited the financial statements of Precision for any year
3. We were not even auditors of any lreo Group Company for the period in which alleged
payment has been made. We were appointed to audit some of the companies of lreo
Group for the financial year 2017-18 onwards.
4. Complainant was group CFO during the period, he may explain
12.3 Since the respondent has not been the auditor of Precision for any year, the question of
levying an allegation for professional misconduct in respect of transactions relating to Precision
is entirely absurd.
12.4 The respondent thus prays that this charge be dropped.
13. Charge -12
13.1 The allegation in the so called Charge No: 1.2 is vehemently denied.
13.2 This allegation relates to the reporting obligation of the auditor vvith respect to the require-
ments under CARO 2016. This is a clear cut case of misrepresentation of the facts by the com-
plainant which were as follows:
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1. There was default in payment of interest for the period October, 2018 to March, 2019 of
Rs. 920.81 lacs by lreo Private limited. It is disclosed in clause (viii) of Caro attached at
page 188 to 189
2. PNB Housing Finance Limited had sanctioned term loan of Rs 225 crores to lreo Private
Limited (lPl) on 19.12.2017 for construction and development of on,.going projects.
3. Tenure of loan is 60 months with moratorium of 18 months
4. Asper the disbursement condition:
5. Disbursement of CTL of Rs. 225 crores shall be done towards construction and develop
ment of ongoing projects subject to following conditions:
a. First tranche of Rs. 150 crore to be disbursed upfront towan:'ls construction and de·
velopment of ongoing project of IPL
b. Ga lance of Rs. 75 crore shall be disbursed only after downsizing of the proposed loan
through the sale proceeds of sale of licenced land to M/s Pacific Development Corpo·
ration Limited (PCDL).ln case, IPL fails to down size the loan by INR 100 crore, balance
sanctioned amount shall not be disbursed, ROI on disbursed tranche of Rs. 150 cro,e
shall be increased by 200 basis points and PNBHFL shall have right to recall the loan.
6. Other conditions: IPL to downsize the loan of INR 225 crore by INR 100 crore thrnugh the
sale proceeds of licenced land parcel or any other sources within 12 months of from the
date of first disbursement In case of IPL's fails to do the same, PNBHFL will have right lo
recall the loan.
7. Even in Cash Flow projections, forming part of sanction letter, it was clearly demonstrated
that there would be no cash inflow from the project till 31 March, 2019 and cash inflow
for the project will start from June 2019 quarter. Accordingly, moratorium of 18 months
was given be PBN Housing. {Page 196)
8. PNBHFL issued notice on 2 July, 2019 for recall of loan.
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9. As per the condition, loan amount has to be down size out of proceeds of sale of lice need
land to Pacific Development Corporation limited. Such sale has not happened. In such a
case PNBHFL has right to recall and loan was recalled on 2July, 2019, beyond audit period.
13.3 As part of the audit procedures performed the undersigned had first studied the following:
a) Reporting of loan default
As required by Clause (viii) of CARO, auditor has to report:
Whether the company has defaulted in repayment of loans or borrowing to a financial
institution, bank, government or dues to debenture holders? If yes, the period and the
amount of default to be reported (in case of defaults to banks, financial institutions, and
government, lender wise details to be provided).
b) Your specific attention is drawn to thE~ contents of Para 44G of the Guidance Note on
CARO 2016 issued by ICA! as follows
The auditor should examine the agreement or other documents containing the terms aM
conditions of the loans and borrowings of the company taken from banks., Govemrnent
and financial institutions. The auditor should also examine the debenture trust deed. This
examination would enable the auditor in verifying the amount and due dates of the pay
rnents mentioned in schedule of repayments provided by the management of the corn
pany. The auditor should then verify whether the repayments as per the books of account
are in accordance with the terms and conditions of the relevant agreement.
13.4 For the purpose of CARO reporting, regarding defaults in payment of dues of financial ins ti
tutions, we performed following procedures:
1. Obtained list of loans/borrowings taken from banks, financial institutions and govern
ment.
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2. Obtained copies of loan agreements.
3. Verified repayment schedules from the agreement
4. Verified, whether there are any specific conditions mentioned for repayment/ recall of
loan.
5. Verified calculation of interest as per loan agreement.
6. Verified payments of insta!tments and interest made during the year are in accordance
with the terms of the agreement
7. Verified Interest accrued and due as at the end of the year.
8, Ensured that defaults in repayment of loan and interest is reported in CARO as per guid-
ance note issue by ICAI
13.5 A copy of the document containing the terms for sanction of term loan for Rs 22~, crores 1s
attached herewith (Pages 190 to 196).
13.6 Accordingly, the respondent had appropriately verified the transactions in respect of the
loan from PNB HFL and had appropriately concluded that there was no failure to refund the loan
based on the conditions it was sanctioned.
14. Charge -13
14.1 The allegation in the so called Charge No: 13 is vehemently denied
14.2 The complainant has referred to SA 240 and SA 250 in the so called charge without stating
the specific requirement which has not been complied with this cannot constitute an allegation
for professional misconduct for any case. Such allegations are required to be specified to the
respondent it has been levied.
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14.3 To set the fact of the case right, the respondent states:
1. Grand Hyatt Residency project was launched in 2012.
2. RERA was notfied in May, 2017.
3. Asper RERA, projects that are ongoing on the date of commencement of this Act and for
which the cor:-ipletion certificate has not been issued, the promoter shall make an appli
cation to the Authority for registration of the said project within a period of th tee months.
4. The Company has filed application for registration on 28 July 2017, but registration is
pending as at 31 March . 2019.
5. In note 35 to the financial statements, it has been duly disclosed that the Company has
filed application for registration of project, but registration is std! pending to be received.
14.4 As part of the audit procedures performed the respondent had ensured:
1. Make an understanding of the provisions of Real Estate Regulation Act (RERA) which was
notified in May, 2017.
2. /\s per RERA, projects that are ongoing on the date of comrr.encemert of thi\ l:..ct and fm
which the completion certificate has not been issued, the promoter shall m;3ke an appli
cation to the Authority tor registration of the said project within a period of three months
3. We verified the application filed by the Company on 28 July, W17 for registration of the
project. 'Grand Hyatt Gurgaon Residencies' with RERA.
4. We enquired from the management regarding status of application ti!Eid by the Company
and verified communication with the RER.A. The Company ha~. also disclosed in the notes
to the accounts :hat Company has filed application for registration of project, but regis
tration is still pending to be received.
5. We searched HRERA web site, there is no such detail available. Even made google search,
there is no r1ention of rejection of registration.
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14.5 We had discussed with the management and were informed that there was no rejection of
registration; and there was not such news in public domain or website of Haryana RERA. Further,
we did not have any knowledge of the order attached by the complainant on Pages 128 to 130
of the complaint document. FL1rther still, all bookings by individual buyers t1ad been made before
our date of appointment.
14.6 The respondent prays that this charge be dropped.
15. Charge - 14
15.2 The complainant has referred to some "Significant issues relating to goint; concern" without
signifying the lapse of the auditor with respect to the discharge of his duties and performance of
the audit procedures in compliance with SAS/0. lt is not po:,.~ibiy to de(ii w1U1 such
staterent as they cannot be deemed to constitute an allegation for professional misconduct.
15.3 The complatnant has further referred to non disclosure of payment due to government
authority in respect of some transaction. Most strangely, the complainant has himself stated
"Please do not reply stating the fact that some of these cancellations ha,1e happened ~:ven
before you took over the audit work.''
15.4 We have already stated in Para above Urnt we have not answered the questions thal tl,e
complainant has been asking following his so called charges. Wf.:: are not required to do so and
in fact we are constrained not to share confidential inforrnation of our clients. Further, we find
it extremely incredible and absolutely ridiculous that the complainant is instructing us how and
what we should reply.
15.5 lt is a matter of fact that:
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l. As per the complaint, these agreements were cancelled before OU' audit period.
2. No payments to Grand Hyatt has been made during our audit period i.e 1 April, 2017 to
31 March, 2019
3. In our opinion, no disclosure of cancellation was required in subsequent financial state-
ments
15.6 Based on the above there was not audit procedure to be performed by us with respect to
this charge.
16.Charge-15
16.2 This is again a case of absoslute misrepresentation of the facts.
16.3 The respondent clarifies that:
1. Balance sheet and profit and loss presentation is as per requin~rntmt of Schedule 3 to the
Companies Act and Generally Accepted .Accounting Practices.
2. At point 15, it is mentioned that lreo Residences spent Rs. n crore 2018-19 and Rs. 62
crore in 2017-18 on material cost. The screen shot attached is of from financial state-
ments of lreo Grace Realtech Private Limited, a separate legal entity. There is intention to
mislead the Institution by complainant.
3. As per flrn:mcial 5tatements of lreo residences Private Limited, amount spent on material
cost is Rs. 21 crores and Rs. 59 crores in financial year 2018-19 ;me! 2017-18 respectively
(copy of Profit and Loss attached on Page 197)
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4. Amount spent on construction / development of residency project has been recorded in

the books of lreo Residences Private Limited. Name of the project is !reo Grand Hyatt
Residency. Bills are in the name of lreo Residences Company Private Limited
5. Project is under initial stage of construction and civil structure work is going on
6. We have verified construction bills as per our audit procedurE~ and have not came across
any invoice in the name of lreo Hospitality, which has been acwunted in the books of lreo
Residences.
16.4 As part of our audit procedures performed, the undersigned had:
1. Obtained ledger dump of project expenses incurred by the Company
2. Selected samples for substantive testing
3. Obtained supporting documents for selected samples and verified for following attrib-
utes:
EL Bi!ls are relating to the financiaf yeBr under audit
b. Bills are in the name of the Company
c. There is proof of delivery of goods/service
d. Bills have been duly approved by the Company
e. Whether TDS has been deducted at proper rates, if applicable
f. Traced amount of bills with entries in ledger accounts
16.5 It is thus apparent that the complainant is mcluding inforr1ation from different and
unconnected with those with which he is making the complaint. The complainant has further
included allegations for the presumed non-disclosure of information which is not ri2quired to be
disclosed under the government statutes. The complainant has further resorted to using pictures
from google earth by supporting his contention by misleading documents.
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16. 6 It has been alleged that expenses of lreo Hospitality have been ,:iccounted in the books of
lreo Residences to claim GST Input credit.
This ls baseless, these are two separate legal entities. We have verified the bills and checked that
bills booked in treo Residences Company Private Limited are in the narne of !reo residences.
16.7 The respsondent thus prays that this charge be dropped.
17. Charge - 16
17.1 The allegation in so catled Charge No: 1.6 is vehemently denied.
17.2 The complainant has n,ade reference to Ind AS 18 and Ind AS 115 without spE>cifying the
specific requirements which has not been complied with and which ought to have been reported
bythe auditor.
17.3 The facts of the matter is as follows:
1. The Company entered into a collaboration agreement with Heritage Max Realtech Private
Limited (l·Hv1RPL) on 2 March, 2016 for development of licensed land of 8.9187 acres 1n col-
laboratlon with HMRPL for Joint development of a group housing colony at Gurgaon.
2. ln terms of the joint development agreement:
a. Project will be developed by HMRPL and IREO undertaking their respective, separate
and specific obligations in the project/collaboration land (para 2.2)
b. In consfderat[on, 22% of the saleable area in the project will oelong to IREO and 78%
wilt belong to HMRPL (para 4}.
c. HMRPL shall pay refundable security deposit of Rs. 429.90 crores (para S)
3. As at 31 March, 2019, IPL has received security deposit against the agreement.
4. The project has not yet launched and no sales have happened till 31 March, 2'.019. Accord
ingly, the Company has not booked any revenue from this collaboration agreement.
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5. As on date of agreement, wmp!ainant was Group CFO of lreo
The contention of the complainant are self explanatory, and they by themselves constitute
enough reasoning that no revenue could have been recognised under the circumstances.
17.4 As explained earlier, there was no conditions met for recognition of revenue as per Ind /\S
18, Ind AS 115 and Guidance note. There was no sale of goods of service., accordingly no liability
for GST and income tax.
17.6 Copy of agreement with Heritage Max is enclosed at page No 198 -239 (full agreerni2nt
not enclosed being too voluminous)
18. Charge -17
18.l The allegation in the so called Charge No: 17 is vehemently denied.
18 2 The complainant has referred to Ind AS 18 and Ind AS 115 without specifying the specific
requirements that have not been complied with.
18.3 The facts of the matter are as follows:
1 IPL entered into an collaboration agreement with Watsonia Developers Private L1mitt?d
for joint development of project
2. As per agreement, lreo will be entitled for 25% of saleable area of the project Watson1a
has paid refundable security deposit to IPL
3. The project is not launched as of 31 March, 2019 and no sales has happened.
18 4 The following audit procedures have been performed:
l. Obtained understanding of Ind AS 18 and Ind AS 115 and the Guidance note on Account··
ing for Real Estate Transactions issued by !CAI.
y
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2. Obtained copy of the agreern2nt with Heritage Max and Wat~.on;a. Prepared brief sum-
mary of significant terms and conditions of the agreement
3. Verified whether the conditions laid down in Ind AS 18/ Ind AS 115 read with I.he guidance
note are satisfied by the Company for recognition of revenue.
4. Ind AS 18 was applicable for the financial year 2017-18 and Ind AS became applicable to
the Company from financial year 2018-19
5. As per Ind AS 18, revenue can be recognized:
Rendering of services
When the outcome of a transaction involving the rendering of services can be estimated
reliably, revenue associated with the transaction shall be recognised by reference to the
stage of completion of the transaction at the end of the reporting period. The outcome
of a transaction can be estimated reliably when all the foHowi1g conditions are satisfied·
(a) the amount of revenue can be measured reliably;
(b) it is probable that the economic benefits associated with the transaction will
flow to the entity;
(c) the stage of completion of the transaction at the c•nd of the reporting period
can be measured reliably; and
(d) th€: costs incurred for the transaction and the costs to complete the trans<.1c
tion can be measured reliably.
6. As per guidance note on Accounting for Real Estate Transaction Verified, revenue can be
recognized when the fotlowing conditions are satisfied:
(a} the entity has transferred to the buyer the significant risks and rewards ot ownership
of the real est.Jte;
(b} the entity retains neither continuing managerial involvement to the degr(~e usually
associated with ownership nor effective control over the real estate sold;
{c) the amount of revenue can be measured reliably;
{d) it is probable that the economic benefits associated with the transaction will flow to
the entity; and
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{e) the costs incurred or to be incurred in respect of the transaction can be measured
reliably.
7. Note on revenue recognition as per Ind AS 115
Satisfaction of performance obligations - An entity shall recogn'se revenue when (or as)
the entity satisfies a performance obligation by transferring a promised good or service
(ie an asset) to a customer. An asset is transferred when (or ,is) the customer obtains
control of that asset
Revenue can be recognized when the entity has no remaining obligations to transfer
goods or services to the customer and all, or substantially al!, of the consideration prom
ised by the customer has been received by the entity and is non-refundable; or the con-
tract has been terminated and the consideration received from the customer is non-re-
fundable.
8. Tested whether the above condition of Ind AS 18 /Ind AS 115 or the Guidance note are
satisfied by the agreement.
9. The Company has not recognized revenue from these agreements due to:
a. The agreement is in the nature of joint development agreement, wherein both parties
will undertake their respective and specific obligation
b. No sale or bookings have been made by the Company
c. No active construction of the project has started
d, There is no transfer of Risk and rewards in favor of any person.
e. The Company has not received ,my sales consideration. The amount received is SC'CU·
rity deposit from joint developer which is refundable.
18.S As explained earlier, there was no conditions met for recognition of revenue as per Ind AS
18, Ind AS 115 and Guidance note. There was no sale of goods of sEirvice, accordingly no liability
for GST and income tax.
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18,6 The ao!icab!e Standards did not permit recognition of the revenue Linder the circumstances
otthe case at the relevant stage during 2017-18 and 2018-19, Merely entering into a Col!abora
tion Agreement does not mean that it is a stage for revenue recognition, Cash flow and revenue
recognition are entirely different issues. Cash flow received as security deposi is refundable
deposit. The complainant has induded such allegations merely to mc1ke the complainant
voluminous. Such assertions are meaningless as fare as an allegation for professional misconduct
is concerned.
18.7 Copy of agreement with Watsonia is enclosed at page 240 to 279 (full agreement not
enclosed being voluminous)
ln view of the above the respondent prays that this allegation be dropped.
C. Use of the words "gross negligence"
19.l Time and again, through the various so called charges, the compl2inant has referred to the
words "gross negligence". This term has not been defined in the Act. lt has not even been defined
in the Code of Ethics published by !CAI. However, the said Code states that negligence per se does
not constitute gross negligence,
19,2 In Black's Law Dlctionary the expression "Gross negligence" is defined as lollows:
"The intentional failure to perform a manifest duty in reckless disregard off the conse-
quenucs as affecting the life or property of another; such a gross want of care and regard
for the rights of others as to justify the presumption of wilful,ness and wantonness.''
19.3 Accordingly, "Gross negligence" connotes higher degree of n(Jgligence; it is negligence not
arising merely from some want of foresight or mistake of judgment but frorT1 some culpable de·
fault."
19.4 As observed in the case of S. Ganesan v. A K Joscelyne [AlR 19.5 7 Cal 33] the Calcutta High
Court observed that "Professional misconduct on the part of the person exercising one of the
technical professions cannot fairly or reasonably be found, merely on a finding of a bare non-
performance of a duty or some default in performing it. The charge is not one of inefficiency, but
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of misconduct and in an allegation of misconduct, an imputation of a certain menta! condition is
always involved. I think, it would be impossible for any professional man to exercise his profes
sion if he was to be held guilty ot misconduct sirnp!y because he had not, in a given case, been
able to do all that was required in the circumstances or that had misconceived his duty or failed
to perform a part of it. I think the test must always be whether in addition to the failure to do the
duty, partial or entire, which had happened, there had also been a failure to act honestly and
reasonably."
195 Council of lCAI vs Somnath Basu [AIR 2007 Cal 29, (2007) 2 CALLT 182 HC, 2007 (1) CHN 3781
the Calcutta High Court ruled that "Failure to rise to the expected level of efficiency in discharging
professional duties - cannot be regarded as misconduct treating such failure as negligent act in
the conduct of the professional duties. In the Division Bench judgment of this Court in the c;;ise
of S. Ganesan v. A.X Josce!yne, Chief Justice Chakravartti cbserved as hereunder:
33 .... Professional misconduct on the part of the person exercising one of the technical
professions cannot fairly or reasonably be found, merely on a finding of a bare non- per
formance of a duty or some default in performing it. The charge: is not one of Inefficiency,
but of misconduct and in an allegc1tion of misconduct an imp1,, tation of a certain mental
condition is always involved. I think, it would be impossible for any professional ffkln to
exercise his profession if he was to be held guilty of misconduct simply because he had
not, in a given case, been able to do all that was required in thE· circumstances or that had
misconceived his duty or failed to perform a part of it. I thir,k the test must always be
whether in addition to the failure to do the duty, partial or entire, which had happened,
there had also been a failure to act honestly and reasonably."
"ln the present case, admittedly, it has not been alleged that the re5pondent auditor
failed to act honestly and therefore, it is difficult to hold that the said auditor is guilty of
any misconduct lt is difficult to hold that lack of efficiency or attainment of expected
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standards while discharging professional duty would automaticaHy constitute miscon
duct."
"Misconduct arises from ill-motive and mere acts of negligence, innocent mistake or er-
rors of judgment do not constitute the misconduct. Even if there is any negligence in per
formance of duties or errors of judgment in discharging of such duties, the same - cannot
constitute misconduct unless ill-motive in 'the aforesaid acts are established."
We would like to further humbly submit that . an error of judgment does not constitute
professional misconduct What is extremely important is to examine whether the auditor
had ever cicted without integrity or with an ill motive; further it is also important whether
the auditor had performed his duties in a reasonable manner. We submit that reasonable
care was taken ln discharge of duty as a statutory auditor and there was no question of
any doubt on integrity or ill motive of the auditor, or any such act or omission which could
even be deemed to constitute a professional or other rnis .. conduct
19.6 As regards the role and responsibility of an ;.wditor, we would like to draw reference to Uw
judgment in the matter of Tri-Sure India Limited v. A.F. Ferguson & Co. and Others, (1987) 61
Comp Case 548. The following principles were \aid down by the Bombay High Court in relation
to the duties of an auditor:
"The auditor is required to employ reasonable skill and care. but he is not required to
begin with suspicion and to proceed in the rnanner of trying to detect a fraud or a liP.
unless some information has reached which excites suspicion or ought to excite suspicion
in a professional man of reasonable competence. An auditor's duty is to see what the
state of the company's affairs actually is, and whether it is reflected truly in the accounts
of the company, upon which the balance-sheet and the profit and loss accounts are based,
but he is not required to perform the functions of a detective. What is reasonable care
and skill must depend upon the circumstances of each case. Where there is nothing to
excite suspicion and there is an i'ltmosphere of complete confidence, based on the record
of continued success in financial matters, less care and less severity of scrutiny may be
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considered reasonable. Whereas reasonable care and skill may be regarded as not exer
cised when, in spite of the presence of unusual feature; in the accounts or other prirna
facie reasons for believing that the affairs of the company may not be in order, the exam-
ination is perfunctory and not sufficiently detailed. One major aspect while determining
that question of reasonable care and skill is whether the auditor was justified in relying
upon the statements of the director or the managing director, and that again must de-
pend on the circumstances of each case and on the nature of the subject· matter which
requires explanation. Whether the subject is one which is not capable of direct verifica-
tion and when to verify properly the result presented in the balance sheet, it would re
quire investigation rather than checking and where there is nothing at all to excite suspi
cion and in relying upon the statement of the management, the auditor himself is de-
ceived, then he will not be held to have failed in the dischc1rg€' of his duties. In judging
whether an auditor exercises reasonable care and skill, it would not be ,Jppropriate to
proceed on matters which have subsequently transpired, but one must place oneself 1n
the position ofthe auditor as when the accounts were audited and find out how Lhe mat
ters appeared or ought to have appeared to a man of reasonable care and skill. Bearing
in mind thes2 principles, it would be appropriate to ascertain 'Nhether the defendants

were guilty of negligence or have failed to discharge their duties properly.•.•
19.7 Honourable Supreme Court of India in the case of H.V. Panchaksharappa vs tCG. Eshwar
(AIR 2000 SC 3344) stated:
»A charge of professional misconduct is in the nature of a qw.,,si-criminal charge. Such a
charge requires to be proved in the manner of proving a criminal charge and the nature of
proof required to prove it, is that of beyond a reasonable doubt."
In view of the above, and upon consideration that the respondent h0s provided point by
point details of his discharge of professional duties, the question of gross negligence does
not arise
I
X4
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D. Conclusions and prayer
20. Wo hnvc clarified in details above that tho complainant has not come with clP,rn hand-; before
the Disciplinary Directorate and his intentions are malafide, and further 1:hat he is lndu1ging in a
phishing expedition to gather more documentation about the compary. It is a fact that the coifr
plainant has resorted to theft of our working file, else he could not have produced documents
that are absolutely the property of the audit firm. The management of ':he IPL has also lodged
complaints for sin,ilar nefarious activities of the complainant. Under such circumstances, all doc
uments that are available in the public domain or may be available with the complainant have
been attached by us. As far as copies of our working fifes, constituting audit evidencP in support
of the audit procedures performed, we have not attached the same. Our client is extrernc'ly con
cerned with the intentions of the complainant to merely assimilate more confidential information
about the transactions of the various entities of !REO, and then use the same to harass them, We
submit that all such audit evidence can be produced tor your verification at the office of thE!
Disciplinary Directorate as and when instructed. No negative inference should accordingh; be
drawn for non attachment of the detailed audit evidence, which shall naturally contain dHaib of
the transactions of the entities concerned, for reasons explained above.
21 The respoml<~nt has demonstrated in sufficient details above that this enquiry could not have
been initiated in the first place. Further the process of law which is mandated und<?r the statute
has not been followed in the instant case; further still the complainant has not come beforP th0
Institute with clean hands; the complainant has an ulterior motive and it is patently v:sib/e that
hf2 h:::is regularly attempted to misuse and abuse the platfonn ur Lhe Jisciplinary !'nechanism of
IC/\1. Each of the allegations, in the absence of the charges of profess onal misconduct, which 1s
specifically required under the Rules approved by the Parliament of the country, are not. even
admissible. The respondent has however provided the factual details and listed the audit proce-
dures to demonstrate how he has been in compliance with the applicable Standards and the
various Guidance Notes issued by !CAL Should you require any additional details or clarifications,
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please do revert back to the undersigned. Under the above circumstances, the respondent prays
that he has been suffenng tremendous mental anguish and agony and this enquiry may be closed
forthwith, and that he should be declared non guilty.
Yours sincerely,
Chartered Accountant
Membership No. 087701
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W'TM/RKA/lVD-7 /117 - 124 /2014
BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA
ORDER
Under sections 11(1), 11(4), UA and 11B of the Securities and Exch,,.ngc Board of India Act,
1992 read with clause 17.l of SEBI(Dh,dosur<.: and Investor Protection) Guidelines, 2000,
regulation 111 of SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2009
and regulation ll of SEBI (Prohibition of Ftaudulcnt and Unfair Trade Practices relating to
Securities Market) Regulations, 2003.
In respect of:
··--l-··r1"AN ···----- ---1--0_r_d_cr Numb._i::_ir_ __
f-c·~_s_~:-_N_···_·()-4-T_N_···-_;:_~_··c_·_o_f_t_h_c_E_·,n_ti~tv'-.·-····_····_···_ _
r---l-+--D__I_J_;_I_,ir_r_i.i1_:<:_d_ _ _ _ _ _ _ \_,\J\CD3_4_9·_\.N_'_ _ _ _~_
.,..i:_.. 117/2014
2 . i Mr K. P Sind1 i \B1PS(i46-.JP 1 [8/2014
················•·l-----'------c
.3. :Vlr. R,1,jiv Siotrh ··j-~!311;;6(i65(; - l l l) /2Dl4
--4-.--+-\Ir. T. C Co~;a·-1------···· f \:\(~1;(;~817.iN. 1:::'.U/2014
l\fa. Pia Singh i ,\.\i\PS64:'16l 121/201,1
-----<
(,. TVfr. Kmnc.:;h,var Swarup j AB(2PS1072H l22/20l4
7. j\fr G S. Tatwar 1 ;\EYPT8G09L 123/2014 . '.
----------l
124/2011
In the matter of complaints of Mr. Kimsnk Krishna Sinha in respect of DLF Limited and
Sudipti Estates Priv,He Lin1ited.
Appt:atancc:.;
For N o!kc.£.fil
Fot DLF Ltd., Mr. T. C. Goyal and Mr. Ramesh Sanka
1. ,\fr.Janak I)wad,iHhs, Senior Adv( ,catc.
2. i\lr. Slrnrdul Shroff, :\dvocatc,
For Mr. K.P. Singh, Mr. Rajiv Singh and Ms. Pia Singh
1. Mr. JJ i\bntt, Semt,t :\dvm:ate,
::2 \Lt·. Sh:11.dul Shroff, .;\dvocare,
For lv1r. G.S. Talwar and Mr. Kameshw,u· Swarup
l. Mr. Sor:nasckhar Sunder:1:;an, 1\dvocan:,
2. l\tr. Para~ K. Pan:kh,
l :-Lr Pranial JayaswaL Lkpu1v General Mnnagn

2. Mr. '.'.iilhil i\lahk. 1\ssi:;tant (;eucral M,m,,ger
Order 111 the vwttff 11( DLF Limikd
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170
dercrrencc ln this n,g~ird, rlw ob:-;(·t-v:1nrn1 tJi' the flon'ble Suprtrne CoL,rt, :,,; :t \V(lrd ,,!
caution, m che matter of :\'. ,\J,m1)'m1t111 PS. /ldpuiicat:it{~ Ojfker, SE:fH. in Civil .\ppenl No;,;
41124113 of 2013, (order ,bted .i\pr.il 26. 2013) i~ worth mentioning:
", /I H'Otd o( ,mttirw:

.!J. .l{i/31, !he mar/2:d n:g111;,1{/f: /l({s /,) dc,d s/,:mi}' ,vi.th m111pcmie., am! thtir Din.:d,n:r t!!d11/,;:,inf!, it1
//ltlllipNl\rtil'c mid dc·ccpt1n· ,kl'f(CJ, {Jhtdcr /r(l{//f(~ ;'/.:. or d,c they 11•1!/ hc_f11,ii1z~ ;,,. lh<'tr rht!)' ,lo pm111ok
orda/y ,111d hcaithv ,gmwlh o/ ihe Se,'fmtics m,rd:d. L:((111111mc 11/F-111,,. p,·11plt •;/ t.hu d!llll!I}' shrwld
k1101;,, tJ a ,1(/1/Jll.) o'/7!/IC whith, 1/ Ill)/ /!FO/Jl!ttr d•,il! with, as ii shoulrl he, will ,rf/i:d I((}/ ot1I, ,{)JIJl/r)! ',
ctYif!Ot!JlrgmJ!!!h, hlf! al'.ro ../rm' th,· injlrm o/jiirc~w1

1 mn·.tl111ent hy J!/rt11111,: i11vest()r:r ,wd also msts r,1 slur
011 fod1i1 '.r .,i:am'tirs mar/4:d. ,Jkr,r,ri;e J/;(}it/d.t;u t/lal wrr ,:01111/tJ' 1Ft!i mil /o/erak "mar/tr:! ,.i!Jl!se" and
Iha! 1/l!' arc ,~rmmcd /ly !ht' "/{!!!,' ,f L.,rm' ': / ·rmffl. dewit, art1ficialilv. SEHi sho,tld t11,1,,111?, /Jm1e mJ
place i11 the .1,•c111i!11's 11.1arl::d 1f tl,iJ cr,,1mt1y am/ 't;.rarkd J"cc"mify' 11 1/ar mo/fl). /)er~hlt with p11wtr ,.md
111onq t1flrl hr .'1/,Ullff!/lllc'II/ 1f the m111pl111ics, m1/i1rJmw!c/y ojic11 t<JIJ!llhlthl tllorc rts/ied i11 ol1r .w!'tci)
thau the .,HhJ,1,ha.i w1ti ihtc.r/111:r i11 t/ii:ir <"OtNf),mit.1: c:·01i1pa111r's ,Iii: ih1·ivi111; 1n!h :m·estor: ,
,:1J11hib1itiow httl Jh,·y ,tn: a di1·1ife-d lo!. Si iH! h,1.>, thtrr/11ti', ?I 1hllv !1, J)1vta'I imw.1Io1~, /11dmd11,rl am!
mlk,:tirN, 1(~t1i,u1 opport1111,Zf/i,· hchm1ir1r u/ Uircdo1;f 1111d 111.,'ttlen (!/ lhe k,!ed compat1i<!.r .rn .:u lo
sa/i:g111ml l!Ji!rl:.:d '.r 111/1:,gn!r. rr
VJ. I note that th· SC:-1 ha~; !wen 1:;:;ucd t•> ,;ix dtrcctnr:; and CF(J of DLF on accuunr of :dkgcd
viol:irions hv f)I J< as they \v,.·rc in charge nt rhc affairs of DJ J· :\I rhe rdcvam urfa: and ,vcrc
involved in the prnce;;s r,f prcp:1rat1on ()t' 1hc HHP/Prospcctu~. in tlm c.a.:oc, tbt: ['luticcc,,
had amhon~ed the RI !J>/ Prospectus and ~1gncd the dedararion~ certifying the cornpl.iancc ut
DIP (;uiddmcs, etc and they cannot escape liabilitv for the acts and omiss.ioa~ found in this
c:is~:. ln thi:; regard, Mr. (; .S. Tahvar ha,; ,,ubmittcd rhar while the other non-executive
director~ uf DLF li;in· bcu1 kit out tn the SCN, alkgations have been kvckd in the SC'.'-
onlv again~1 ;\!r Ta1w'1r ! [,: :dc<, suh1rnttul d1i!t hi:, rok on tbe Bo:11:d of din:cwrs ufDLF i~
that of m'crsecmg high level srraregv and he had no personal knO\vlcdge or invulvcmem 1n
the ,;ubjcct inaner uf tb.· prncccdinp:~. hittlwr, he played a ,;i.mih1r non ,,;,:ecutive nile 011 the
gl.obal board" c,f Schlurnbcrgcr Limttcd, !·oms S\' & N1\, Pcerson i>k. nnd the 2m-cnlllll'
,l ,·s,
bodws off ,ondon Business School and the l ndian School of Bu~1ness. l note tba.1 ill the rime
of filing of prnspcctu, of l}lL f\Lr c; S Ta.lwar \Vas the non-executive director o:f DLl'. l
nolc that tile Sc:N does nut lmng, .. out a1w,' rnatc:rial to sbO\\' that Mr. Talwar, \vhik actinQ'~ in ' ,.
his capacm· ;,s a notH'xcrnr1n, director of DJ ,1;, participated or was involved 1n the day to
day du.:1:,t 1m rnaku1g ut DU·. !11 v1cw 1.,t 1hc~c facts and circ,mstancc,, f g1\·c benefit ,H
doubt to :Vir Tah.var.
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50. Considering the ~1bovc, I, in order to prorccr the inrcn:sL of mvcstors and 1he
securities rnarket. in cxerci,e of the power, confet:rl:d upon me un<kt section 19 of tlw
Sccuritic:, ,rnd F.xchange Bo:mJ of l ndi:i ,\ct, 199:2 read wid1 sections l I. l 1,\ and 1 I!'>
thereof a,nd regulation l l ihe Pf-'l q·p Regulations, clause l7. l of DIP ( ;uiddines and
regulation l l l of th<.: ICDR Rcguhuions hereby restrain du: fi·,llowing entitfos fr<>m accc;;sint'
tlw sccunnes market :wd prohibit 1hcn1 from buying, :idling ot otht:1'\\1s,: deding 1n
securities, (h!'ectly or indirectly, t11 any manner, whatsoever, for th(: period ,it three \'ca.rs:
Sr. No Name of the Entitv i PAN

DLF Lirnitcd ; A:\f\CI)H94N
l,
Mr. K,. P. Sin1,:h , I :\BlPS64MTl__, __ ______....i
!
1---~::I_,__rv_,1_r_._R_:1-'-.ji_v }ingh :\B1PS<i665G
4, Mr. T. C. (,oval !\;\(iPG81731',:
-----+
,__ _ _S._+Ms. Pia Singh
,_---=-,,- '
""""'"""«<.
_________ .:\_:_\__A
__J_)S_'c_)·_t3_6...i}_ _ _._______--i
1
Mr. Kamcshwar.?.~van11>, , ,,....J_1\Bq1?S1072lT ..__
7 i\lr. Ramesh Sanha ' :\B,APS13,lOL
3L A copy nf this order shail rw ~ervcd on aH recog11izcd stock exchitngcs and dcpo:-;1tories t/J
ensure that the direction gin-n in the above para arc complied with,
52. This onler shall come imu
Date: October 10'\ 2014 llAJEEV KUMAR AGARW'AL

Place: Mmnbai WHOLE TIME MEMBER
SECURITlES AND EXCHANGE BOARD OF lNDlA
() rdrr iH th,,
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ffY HAND DELIVERY, E~i\'1A(L & REGISTERED POST A.D.
To,
Ajay Kumar Jain, Deputy Secretary,

Director Discipline, Disciplinary Dirnc:tornte,
Tlw lnsti tuw of Chartered Accountants of Ind.ia,
IC!\! Bbawan, lndraprnstha Marg,
New Delhi l !O 002, India
Ph Ol l-301 i(M36. '435/437
Complaints brought by Mr. Ramesh Sanka in respect ot' the IREO Companie~
and Funds and their employees and managers against S.R. Batlihoi & ni. LLP
(ICAi Finn Registration Number: 30l003E/E30000~), member firm and
nffiliate of Ernst and Young in India
Various other complaints brought by Mr. Ramesh Sanka set out in th,, text of
tht~ ?tttcr beiovL,
Reference: Letter dated 12 August 2019 issued by om· counsel, Trileg:•l
We~ write to you as one of the largest offshore international investors of the IREO Group of funds
and companies. W.: have been constrame<l to write to you in view of the seri<,rns issues that have
arisen \Vtth Mr. S,mka under the legally binding consultancy agreement <Yltcrcd rnto bctvvcen \Jr
Snnka and TC!. Fund .l\i.fanagement Limited and Axon Capital LP (TCI and Axon).
As summa.rw::d m the letter dated 12 August 2019 from our counse.1, ·:·rih:gai, Axon and !Cl
rt:tam0d ~.fr. Sank a as a consultant in respect of the IREO Group of funds t.nd companies \fr
Sanka was paid a very s1gnifkan1 amoLLnt of money for h1s services and fur v,hm we beht:vcd w;1::
,he accurate rnfunnation he was supplying TCl and Axon do not accept that his rnvolvemcnt rn
this ma(ter has been as a whistleb!ower, as be was under cl,:ar obligations under hts con:;ultancy
agr,x:ment to Axon and TCL
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/\s stated in Tri!cgal's letter or 12 A.ugusl 2019, ,1vc hav,; recently beconw aware that Mr Sanka
failed lo disclose cer1ain key and material facts to us. lt is stated that we would not have filed then
original complaint wi.th your good officoe if such mat0rial mf<.lrmation \W\,; not \vithhel d from us
Our concerns ahou1 Mr. Ramesh Sanka and his actions relate to the mcomplete intcmnation and
misinformation supplted by hrm to us and the campaign he has continued to wago against the IREO
Grollp of funds and companies, despite our request that he now desist, which has included pursvng
proceedings against a large number of parties and governmental bodies n~quiring them to take
action
Furlht:rmore :\tfr. Sanka has demanded a large amount money from Axou and TCI, not due to l111n
and in excess oChis cormactual rernunerntion, m return for ceasing bis campaign agamst the lREO
Group of funds aml companies.
\V-:: arc in the process of trying 10 reitch agrecm~mr v,i th the IREO funds Irnd companies m rcsoiv:'
the issues between us. This includes replacing the existing manager of the lREO fonds ,u.d
companies with a reputed institutional, 1ndian asset manager.
Due diligence ha:; also been carried out from time to time by vanou::. lenders of' iRFO fuwi~
Furthermore, the proposed replacement rnanager has afao been conductmg ti:-:tcnsive due diligence
Neither of these parties have raised any concerns of substance with us or that we are aware of wdh
the dtsclosures and accounting treatments in books of accounts ofland-owning comp,w1es in which
advances had been paid by IREO Private Limited and IREO Grace RcaLech Private Limited.
Axon and TC l are currently in the process of i ni t1atmg legal proceedings against rvl r Sam;a ;,, a
rcstdt of what believe to be flagrant breaches of his consultancy arrmgements
\Ve write to confirm that we do no! support any of the ongoing actiors ,nd complai1ns ot· 'v!r
Snnka in respect of the IREO frmds and companies, including any comnl:11nts to your il<md ofViu:
Ple,ise do not hes,tate to contact the undersigned in tbc 0vent you rcqrnrc nn:-; further mfrlrmat,on
fiJease acknowledge receipt of this letter
Dinakar Singh
Chief' Executive Officer
i\xon C}1pitat LP
1':nd. Letter dated l. 2 August 20 t q issued by our counsd. Tnlegal
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174
l/l TRILEGAL
Din:cwr Discipline
Ajay Kurnar Jain~ Deputy Secretary,
Di'.>cipfinary !Jirc8toratc, 1
fb1: lr:~tituw o( Char!,:rc'.d At:comH;:r·w, ,,( (;1diH,

JC/\! ffoawan, fmirnprasthu Marg,
'\~w Delhi. l lndi<e
Ph: Ol 1"30 i i(Vi.16/4351417
Enuii: '!s1,i,,1.i.¼!i,:'f.'··''
Suhjeet: L Cnmp!:1int Adrnnwicdgmcnr 'Ii(.>. PR 533/2018 again.st S.R. Hallihoi & Co.
LJA' (iCAf .Firm Rcgi~tn1Uon Number; 301/)0JE/EJOf!00:5), mcmller lirm
and affilil1l~ of Enis! mid Young in fodia.
2. Various other compil1i11tN hrnugh! hy ·'.\lr H.umt:ii1 Sunh,i ,d

of the letter below,
{)n :r; ()ctob~r ),0 l if, The ChiL!? ~n ·,, l: vtstrr ::1,r F:,,;n\i
1
) at:d /\xon P:1:trn.;!'7; LP· and 1\;s..Q{; fn',;,,:;--nu:i;)~:,ai~ L l'

nad fikd
By letter dated 1R Jan:.rnry 20: q,

Cornp lai.nr.
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1/l TRJLEGAL
rnisi:ifurr~Kitbn suppHcd by hin} :.:_; TCl F\ind LP

('!'(.'[ :!nd 1\xr.}rt\ h1t:iuding in t'•~sp(:(,,'.i.
th~
, ( :1 .1:1(' ,'\,\on du
!\:, \Vff~ und(:r
TC1 ~H;d i\x..:,n .~l~'lv~: ri.;ccntly b~(,OfftC ,)vvarc lhut

nm:.~?rbJ i:10,:"\ to (rlern, \Vhich haij \VC and
~t(;;;;·t initlut~1..~ :.~J Hu~ (tbtitdi.('. of Ch1ntr;._:d
TC i ~tnd. As.on nre -:::urn:nt'iy ~11 :h:: prnti::~:i of

o( V/:~::1: Th(1 y :,e:ii-eve to b:•
Other comptaints
iVh:mbt·r',hip :'lo. of
tln- Ykmber
(:()mplaint Complaint fi'ikd
it No. Compluin! Rd: No. Agains( 'iVhom
Filed On ,\~ainsl
Compl:1ini was
.Filed
93
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176
Ill TRILEGAL
t:A.
Sh1:rna
!\irtncr of iV!/c; Vi;ay Rai
1& Co.
Chanen~d !$:c,n1ni'.inr,
10S, 3rd Floor,. :<an\:frn. 1
Hou~~c,
!KarJn1pL-rZ\ CDni;ncrc i:J[
l('ornµl~x.
NL:w Delhi (1 I
Ct\. foihlmrat
;u<.:n I K )9"J\lig:, l 8 C,·\ Nitin Ch1;1t~1,

I i ! . /,, GI 1 2. .:\nkrn·
Apa!"lllt'.l'.[,
. P.<l ~d 1.i n1
\/ lhat.
N:.:w !)elhi ~ : lC 063
S·O,:i \ 8 CA .i\nil Kun:ar Gud 083 I 'fi
Pilrtl~r onv!h. Anil
\:mnita & (
( 'imner<.~d 1\ccoi,_rn.t~v1t ;;
i86, UJM Silt: i
R<;iindcr
'\(:\V
!k;hi - ! 10 060
!1nYt e::k~~d n5' t-o refer} r:c :..~; 1((1l c:. nn1.;[~1..i1b i,1>JLk by C=~?ii, i> ~: r<:!h.~~
hy i\,h. Sanka hirn~;clL Th<h< re;.,_:v;i:-1: :o thL,; Jcn;..;r a:~ ·;~Cl's ~ind ;\x-;,r: ~~T~}Llp'l
:.tti.'.
1
~
:J;\~ l:T•/:~s1nrs ir the IR Ff) F:.u::ts :1nd \Wt bc\1t,, vc your institu.1e sh~!uld h.: r :ad~; a'Ndrc
1
:~i;tc
of ?vir Sunkd :::rid !:h n:ot iv";:,,,, and bt,k of

theft di;;,;\;l (kn Hn,2~s -with _\ifL S::-mki'.t
();:\ t :i~:n!." ($CHpla::11

:)( i\'!r, f11!i.nr;·i:,1Un1: iH.: \.:t\)Y!dl'<,L I le :~ad
nn (T si1nUar fac!uai .nkttJ ix and
;1r..:s5t~rc on the '. fU-:O I-" urt.;, \Ve
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}fi TRILEGAL
A,h1:;h Flh:rn
Trifogai
CrnJH$t;[ fi;r The Chii1~in;n';l lnve,..;tint~in :-'~md j, rn,nda.tiun (t ;K): 't c: F,.-:rd \-'ia:-,a\?~~rw.:-H f
95
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178
HARYANA POLICE CITIZEN SERVICES n;'1;q1011 ~ ;;:na1'1<fi tl'cIT)

FIRST INFORMATION REPORT
(limier Section 154 Cr.P.C.)
~~ftcrrt
(trRT 154 ~ ~~ ~~)
1. District(~): GURUURAM P.S. (m;;rr): SECTOR-65 Y car (~}: 2020
FIR No. {ll.~ft. ~.): 0058 Date ( ~ ) : 30/03/2020

19:21
2. S.No. Acts(~) Sections (m-u(i!)}

(sn.~.)
IPC 1860 381
!PC 1860 409
3. (·a) Oceui.Tt'nce of offence (3ftRltf ..P..

cp1 ~ ) :
(b) Information received at P.S. ( ~ ~ Date (fa;;:riq;): Time(~):

~ 1lf'Ccf ~): 30/03/2020 '18:00 hrs
(c) General Diary Reference · Entry No. (,;rfcl~ ~.): Time(~):
{i);;J,,'i!J-!ill ~ ) :
030 30/03/2020
·18:58 hrs
4. Type of Information(~ q;r ~ } : Written
System IP (3ff$11T): 10 88 233.14 2 31/03/2020 10:58:20
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HARYANA POLICE CITIZEN SERVICES {9A.4!0ll ~ iil"l~<fi mrr)

FIRST INFORMATION REPOIU:
(Under Section 154 Cr.P.C.)
~~fttftt
{mu 154 ~ ~ ~ c6' ~ )
.5. Place of Occurrence
System IP (31~}:l 0,88.233.142 31/03/2020 10:58:20 2/10
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HARYANA POLICE CITIZEN SERVICES rnR.tuo11 ~ <r11a1fi41 ti~

~~ITT)t
{tlRT 154 ~ ~ ~ <fi' alRf)
6. Complainant / Informant (~cfi14ct4k0 I t(iliiilcfiffi):
(a) Name (;:rr;FT): SU BASH LAHR! Authori1r.:d

Signatory
(b) Father's/Husband's Name (ftror/q"Rt ,;fiT ~ ) :
(c) Date/Year of Birth(~ ~ I cfli): (d) Nationality (~lftif): INDlA

1975
(c) UH) No.(<{~ zj-.):
(I) Passport No. (41f1Cfll zj-.):
Date of Issue(~ ~ ~ ~ ) : Place of Issue(~ ~ i.:fiT ~ ) :
(g) Occupation (ixicffll4):
(h) Address
('t@l):
S.No. Address Type (qm cfiT Address (tfaT)

t;fcfi'R')
Present Address lRE() Campus, Scctor-5(). SEC IOR-65.
GURUGRAM. I !ARYAN/\. INDl1\
Permanent Address lREO Campus. Sectnr-59. SECTOR-(l5.
GURUGRAM, HARY ANA, INDIA
(i)
Phone number(~ 'i. ): Mobile {JTiiil$cl ff.):
7.
Details of known/ suspected/ unknown accused with full particulars(~@ I ~ I 3ul'RT
~ cfiT ~ fc.lct{Of ~ cfClt.;;):
S. No. Name(~) Alias (34oil.J.I) Rclativc's Name (~ffitR ,;fiT ~ )

{sfi.i.)
Ramesh Sanka Father's Nam-:: [swarudu Sanka
System IP (3fl$-cfr):10.88.233. 142 31/03/2020 10:58:20 3/10
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HARYANA POLICE CITIZEN SERVICES rnR410ll ~ qJl;iTft<fi' ~l

EJRST I~l\JATlON REPORT
~~~
(m:TT 154 ~ ~ ~ ~ mRT)
8. Reasons for delay in reporting by the complainant/ informant {~cti14dcfia1 I -tj.__il;;{fcfiffi ~

ftq)t ~ ~ ~ ~ qi' <fi'R"OT'):
9• Particulars of properties of interest(~ ;flJ.qfc;:t cnT

~):
S.No. Property Type (:a;i:::qf@ ~ Sub Type (3'r ~ ) Value( In Rs/-)(~ (:q
(~.i.) ~))
~)
DIGITAL SOFTWARE Others 17.0O.OlLOOO.OO
10. Total value of propedy stolen (In Rs/-) ( ~ ~ ,HJ-qR?J criT ~ ~(~ it}):
17,00,00,000.00
l l. Inquest llcport / U.l). case No., if any ( ~ ~fffi fttnt / <I_.i\'.~ i., ~ <fi1f trr):
S.No.
{~.tl".)
12. Firs! Information contents{~ ~ ~"<:f):
~ TJcFi ~ ~ 609-DSDT.28.03.2020 l7483/CP/2019 1/\PR DT.27.12.2019 cTTc; ~

3rffi ~ rn 41-&aJ1J-t mo=rr i:n- ~ ci ~ GJTt ~~er~ mr ~ m 'fl'
6 ·'To, The Station House Officer, ps badshahpur, gurugrnm. Haryana Complaint again-,\ Ramesh
Sanka. S/o Eswarudu Sanka, Rio M- 161 lB. The rna1.molias. DLF-\/, Cinlf Coursc Road.
Gurugram-l 22001 and other unknown person frlr ofJ~nces punishable under Sections 380. 381, 384.
403,406,408.420, 464. 476,499.600 r/w !20B IPC along with other relevant provisions/sections. Sir.
lREO Private Limited (hereinafter referred to as 'Complainant Company') having its cnrporate olli<.:e at
IRLO Carnpus, S\.:ctor-59, near Bd1rnmpur. Gurugrnm. through its Auth,ll"ih..:d Person is filing the
present complaint The Complainant Company is a wel!~known Real Estate Developer and is i in thi::
business of developing Group Housing Township. Commercial and other projects in and around
Gurugrnm. A copy of the Board Resolution passed by the Complainant Company in favor of the
Authorized Person to file the instant comp!Hint is annexed hcre,vith as /\nncxurc- l That Ramesh Sank.a,
S/o Eswarudu Sanka. Resident ofivl-16118, The nurnnolias, DU:-v, Golf Course Road,
Gurngram-122002, (hereinafter referred to as '/\\.:cus~d Person'). who was tl,e CEO of the Complainant
System IP (3ffttjt): 10.88.233.142 31/03/2020 10:58:20
99
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HARYANA POLICE CITIZEN SERVICES {$ft.4!0il ~ o11a1ft.ih ~m)

(lJmlcr Section 154 Cr.P.C.)
~~ft,:rrt
(URT 154 zjr i;®im ~ ~ ~ )
Company from 03.07.2014 till 28.12.20 I6. Accused. Ramesh Sanka, during his tenure as the CEO was
entrusted by the Complainant Company the moveable property of the Complainant Company ,vi thin the
office premises situated at IREO Campus. Scctor-59, near Bchrampur. Gurugram or otherwise.
including but not limited to laptops, server, emails, documents. agreements, data, information. land
holding details. customer details, costing and pricing details and details oftrnnsactions and business of
the Complainant Company and all other related and incidental documents. [3y virtue of his position of
CEO. he \Vas entrusted ;x;ith all the proprietary information, data. documents, records and financial
statements of the Complainant Company. In terms of bis appotntmcnt agreement, the Accused Ramesh
Sanka had expressly agreed that he shall maintain confidentiality of all documents. data, records.
information, etc. of the Complainant Company that were 1cntrnsted to him and return the same to the
Complainant Cornpany on hb exit from the Complainant Company. The accused Ramesh Sanka had
expressly agrced unckr the said appointment agreement not to issue, circulate, publish or uncr any false.
defamatory. disparaging or criticizing statements. remarks or rumors about the Complainant Company
or any of the shareholders. members, partners, affiliates. officr::rs, directors or managers of the
Complainant Company. A copy of the Appointment Agreement dated 03.07.2014 is annexed herewith
as Annexurc~2. The Accused Ramesh Sanka at the time of exiting the Complainant company. signed an
Ernp!oymcnt Separation Agreement dated 28.l2.2016, wherein he represented and undertook as
under;!. To safoguard confidential infr,rmatinn including prowction of docurncnts from theft
unauthorized duplication and restrictions on access, 2. To not divulge or rumish any inh,rrnation
received during the course of employment rn any person or any entity or any type of transmission or
removal or transport of confickntia! information from the premises of the Complainant Company. 3 To
hold in tnts1. During and after the term of cmployrnent and ~eep confidential any information or
kmnvkdge to any third party 4. That all written records in the custody of the Ac,::used are and continue
to remain the property of the Complainant Company, and none of them have bct:n retained by the
Accused Ramesh Sanka 5. That a!l records nnd copies thert'.of had been harnh:d over lo the Company, at
the time of the execution ofthe Separation Agreement 6. Employee further agrees riot to \.'.ause the
transmission, removal, or transport of any Confidential [nformation from the Complainant Company's
premises, facilities etc., except as necessary or desirable in the course of Employee's employment with
the Complainant Company, without the prior written approval of the Complainant Company: 7. The
employee ,vill bold in trust keep confidential and not disclose to any third party any confidential
information, trade secret or invention (ckfincd hereinafkr) of the Company. The employee undertakes
to keep the Company indemnified and harmless from any loss or damage cause to or suffered by the
Comp<my on account of such disclosure of Confidential Information, int\mrn:.tion or knowledge
concerning an invention or Trade Secret by the Employee 8. The Employee acknowledged and agreed
that al! material related to Confidential Infr,rnrntion, Trade Secrets or invention including but not
limited to books. documents, att work drawings. layout. designs, plans, blueprints. sketches, computeL
software, data, research material, in formation, customer details and records. land records, details Of the
records ol the agents or consultants of the Cornpany, aud10 or video tapes. records and account relating
in any manner to the business of the Company, and/or its .Affiliates, whether prepared by the Employee
or otherwise com.ing and the Employees' possession arc the exclusive property of the Company and
shall be returned to the Company upon the Termination Date (i.e. 31" December 2016). A copy of the
System IP ($):10.88.233.142 31/03/2020 10:58 20
\ cs a
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183
HARYANA POLICE CITIZEN SERVICES rn~,!HOlf ~ ifldlftifi ~ }

FIRST INFORMATION REPO[ff
~~fttnt
(mu 154 ts~~ <fi" ~
Employee Separation Agreement dated 28.12.20 l 6 is annexed hercv,,ith a:; Anncxurc-3. Accused
Ramesh Sanka has dishonestly taken the following movable property i.e docwncnts including but not
limited to (i) confidential and sensitive information of the Complainant Company continued in
Commercial Arrangements/ Agreements/ ~foUs and copies thereof: (ii) Title Deeds, (iii) Confidential
Agreements and Financial Statem.cnts. (iii) Blank Documents, (iv) Company Stamp, (v) Various matrix
of Contractor Information, Brokers Information, Customer Data, (vi) Emails. and (vii) other valuable
data in son and hard fhnn regarding several projects of the Company including Gurgaon Cnrridors
Project Bhiwadi etc. out of the possession of the Complainant Company without the Complainant
Company's consent Also, the accused Ramesh Sanka had/has with dishonest and malafide intention to
cause unjust loss to the Complainant Company, prepared fabricated documents. seals and impression
and the same have been! are being used with intent to cause personal benefit to the Accused and
damage to the Complainant Cornpany, A detailed list of documents, amongst others. stolen by Ramesh
Sanka and being misused by the accused persons is annexed herewith as i\nnexurc--4 fn fact taking of
such data, records and documents by the accused Ramesh Sanka has been admitted by the accused
Ramesh Sanka himself in his \vritten statement given in the matter of dispute betv,e1:.m ·rm;
CHILDREN'S INVESTMENT FUND FOUNDATION (UK) (a company registered in England and
Wales) and (i) lRE0 JNVES'l'MFNT HOLDING HI AND IV CCHNVESTMENT, LTD. (a company
registered in Mauritlus),(l0 fRFO tvlANAGEMENT L LTD. (a company registered In Mauritius). ),(iii)
lREO CAPITAL IL LTD. (a company registered in /'V1auritius). (iv) IREO CAPITAL CO-
1NVESTMENT, LTD. (a company registered in Mauritius) at Para 26. The n:kvant portion Is extrai.:tcd
below l<1r your ready reference. 'Other documents arc lntcrnal WO documents, which t (i.e. the accused
Ramesh Sanka) retained. It is customary li.;r Si:nior employees, such as myselC to retain access to their
emai! records and other documents even afier they icavca business in India l~.ir the puqlo:..c of b1:i11g
able to respond to queries which be my raised by rcgulalors or statutory auditors. Thar was understood
In my case." In fact all the details n-1entiom:d and documents annexed with tl-.t: said \.vitncss statement
clearly establishes that the same have hcen stolen by the A.ccused Ramesh Sanb from the C()tnpany. I\
copy of the witness statt.:mcnt Is annex1;;d herewith as Annexure-5 The accus,:d Ramesh Sanka with
illegal designs. dishonestly., fraudulent imentions and in a pre~planned matm:r had dishonestly
committed th,dl in respect of the movable property in the possession of his employer i.e. the
Complainant. Company as immediately after receiving full compensation under his separation
agreement. it has now come to the knowledge of the Complainant Company that the accused R,1 mcsh
Sanka with an aim to cmise wrongfi.I! gain to hirnsdf and wrongful loss to the Company had mack false
claims and allegations to investors of the Complainant Company sometime in late 2017h:ar!y 20 l 8 that
the Complainant Con1pany and its management had committed fraud in the Complainant Company and
misappropriated tht: runds of the Complain:mt C'ompan.Y thus misleading tht: investors of the
Complainant Company to engage the st."rviccs (1f the accmcd Ram;;;sh Sanka to providc alleged
Information, data and relevant knov,.ll'dgt: that the accused claimed to have in his possession with
regard to the alleged fraud and other misconduct by the Complainant Company . its officers, employi:c:-:
and related entities. by entering into an agreement \vith some of the investors of the Complainant
Company sometime in early 2018. It is worth noting that the said alleged claims and allegations mad\.'.
by the accused Ramesh Sanka against the Complainant Company were dismissed by the Hon'ble
System IP (3-nfcfi): 10.88.233. 142 31/03,12020 10 5820 @:t'tt)
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HARYANA POLICE CITIZEN SERVICES rnR.zi1011 ~ ~ ~)

FIRST INFORMATION REJ>ORT
(linder Section 154 Cr.P.C.)
~~ftcnt
(UTU 154 a:s' ~ ~ cfi atra)
Supreme Cowl. It is the understanding of the Complainant Company that the at;eu:;cJ Ramc::;h Sanb
demanded and received an amount of 2 Million USD (i.e. about Rs 14 crore:s) from such investors. ln
addition to said huge amount of fees, the accused pt:rson also made the inve::;tors pay millions ofrupel-~
of fee to his associated lawyers. It is requested that accounts or the a-:cused per-;un he investigated to
ascertain the huge amount extracted by the accused person from the investors and C\)py or the said
agreement agreement/arrangement between the accused .Ramesh Sanka and the investors may be
obtained from accused Ramesh Sanka and/or the inwstors and the details of' all payment rnadc by th~·
investors to the accused Ramesh Sanka. Thus it would be clear that by committing theft of the property
of his employer Le. the Complainant Company. the accused Ramesh Sanka caused ,vrongfi.d gain
himsc!L Not only did the accused R.arw:sh Sanka caused \vrongful gain to himself but also causcd
wrongful loss to the Company, inter aka, in as much as. Huge amount of legal fees paid to lawyers h'
contest the frivolous legal cases filed by the Accused Ramesh Sanka and/or by Investors at the
investigation of the accused Ramesh Sank.a against the Company and its various ernployt'.cs. Irrep:irahk
damage rah le ti mine to the name, reputation and goodwill of the Complainant• Company and its
senior emplnyees caust:d due to the false propaganda. rumors, etc. carried out by the accused Rame:-;h
Sank;i himself and/or at his instigation by the investors in social media, newspapers and electronic
rncdia (this fact can be clearly borne out by carrying out a seiirch on (}oogle about the same) and
lowering the image and reputation uf the Complainant Company, Its directors, Officers. associate:-; iu
the eyes of' the public at large.• Huge loss to the operations of the Complainant Company as th<: f;thc
propaganda unleashed by the a-:cused Ramesh Sanka caused the lenders to refuse to sanction mud1
neeckd credit f;J0ilities to the Complainant Company and caused a drastic de,cline in sales of apartments
or the Complainant Company as prospective customers were nervous about buying properly developed
by tht~ Compiainant Company and its associates. The Joss caused to the Complainant Co.mpany by lite
illegal actiom; or the accused persons nms into hundreds of crores of rupees. It would be relevant to
mention here that the very investors to whorn the accused Ramesh Sanka had miskad to cxtrai.:t nwn,:.,
from tht!m came to know about the true design of the accused Ramesh Sanka and It i.s the understand in\.!.
of the Cornplainant Company that vide lette;_ to authorities, the investors have clearly stat.ed thm thc -
accused Ramesh Sanka has provided rnisinfrmnation to them and they have doubts about the aceur:1c\
of the information and doubt about good fhith of the assistance and s~rvices provided by the AcetbC(i
Ramesh Sanka to the investors. It is requested that copies of such letters may b,.: obtained by _your g\iml
sel r from the investors. 5. The Accused has also frirged documents and electronic records for harming
the reputation of the Complainant Company. Also, the Accused has made counterfeit seals and stamp:-.
of the Complainant Company and the same have been/ are being used by the a(:cuscd to give the
appearnncc of authenticity to fi)l'gcd documents. The Complainant Company has reasons to bdicve th:it
while acting a.s the CEO. the accused has falsified accounts of the Complainant Company and infringed
the copyright or the Complaint for unlawful gain in the usual course of business. It would be relevant lo
note that a cornplaint was fikd ,vith the sarne Police Station dated 23/04/2018. lt is also relevant Lo 1wk
that at the time of filrng of the said complaint, the Complainant Company was nm aware of the
agreem1:111 between the ac-.:used Rarm:sh Sanka and the Investors (Annexure-6 hereul) In view d the
factual ])!)Sit.ion staled in the foregoing paragraphs it would be clear that the a..;cused Ramesh Sanka ha,.
inter a! ia committed theft of tht; movable property (i.e. doeuments, data. in formation. records, etc.} nt
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185
HARYANA POLICE CITIZEN SERVICES (~~?.!!Ult ~ irlli:ltf.t'ti ~ }

_FIRST JNFORl\'fA l]QN REPORT
~~fttlrt
(trm 154 ~ ~ ~ ~ oF<1)
his employer i.e. the Complainant company and caused wrongfol gain to himsdf and vv'rongful luss w
the Complainant company. lt ls also clear that the accused Rarncst Sanka has committed the ollcnct: ot
cheating/breach of lrnst, defamation. etc. as well. Thus the accused person along with other persons is
guilty of offences under Scetions 380, 381. 384, 403 406, 408A20,464.476A99500 r/v l 20B !PC ..dong
with other relevant provisions/section: of IRC and other relevant provisions uf law and investigate the
rnattcr and bring the guilty to the book. Yours Truly. For fRFO Private Limited (Authori;,.cd Signatory}
Encl.:
l. i\nncxure-l - copy of Board Resolution 2. !\nnexure-2 copy of !\ppoinlment Letter 3. Anncxun.::-3
· copy of Separation .t\grce,rn:nt 4. Anncxurc-4 ·· · List of documents, inforrnati,,.Jn, re.:.ords. etc of th.:
Complainant CDinpan taken by accused Ramesh Shanka 5. Annexurc-5 copy of witness stakm~:nt ul
accused Ramesh Sanka Anncxure-6 - copy of the article/ lfon'ble Supreme Court judgrnenL 3M m-;;:rr
:- 3™ 3q~lcfrl ~ ~ ~ ~ ~ ~ ~ J1'iro'tr ~ T ~~ 'cf, ~
mu 3s 1,409 1Pc ~ ~ d ~ ~ fitq:;1~-R ~ ~ ITT#f -err 3"Cn.T9Tf ~ 3q:f1cfe1
mum 38L409 IPC cf, 3f'Jlcrf ~ ( 1 ~r ~~ 4-,J:9.!j<'..{ ~ ~ *ITT cFl' ~ I '311' sfcfi'
~ ~<Fr ;i~Rit-F?c: ~a~ ~lftm ~ ~ ~ ~ ~ rtr t1 ~ q-:i1c1&fl ~
cff 3ffi<q' ~ ~ 3fT"JTim efil.ticll~ ~ ~ - Jr rn ~ $I ~ f 3 - ~ ~--r,;:r i\S I
c;Niq;,t ~ 3m it ~ ~ I <rg ~ lNSP/SHO DINESH KUtvlAR cFl' ~ ir d
~d[qfl
13. Action taken: Since the above information 1·cvcn.ls commission of offrncc{s) u/s as
mentioned at Hem No. 2.
(<frr "JT<ft cfil4cH$) : ~ 3G·d<tct @liricfitfl ~ tf(ff 'm.>RIT ~ ~ w:RT1t:f ~{<A ~ - ~
11G t. 2 * ~ mu * ~ t.):
(1)
Registered th(! case and took up the investigation(~ a;;1" ~fT ~~ ~ - - ~ ~
~ ~ Rank {tra'). Ass .. S[ (.:\ss1s1.ant
~): or ( <IT} Sub-[nspector}
(2) Directed (Name of LO.) (-am ~ <fir ~ ) :
Deepankar
!'.o. {ff.): 2700CiN to take up the Investigatfon (i:ITT' ~ 3Tcr;t 'CJRf ~ ~ .t'
fmr ~~r ~ -.rn:TT) or (m)
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HARYANA POLICE CITIZEN SERVICES rnft4IOII ~ vrmft:<f> lfqf)

~~ftcrlt
{URI 154 ~ ~ ~ ~ ~ }
Directed (Mobile No. ofI.O.) ( ~ ~ qi]' ff!ilfi$<H ~): 91
(3} Refused investigation due to { ~ ct fR'tr); ~ ("qr cfTTt(l'f ~ ~

District ( ''?1 t>t1 ):
m)
(4) Transferred to P.S. (l!fl'oir}:
on point of jurisdiction (cfil ~ ct

m tH·HlH~a).
F.l.R. read over to the complainant/ informant, admitted to he correctly n:corded
and <l copy given to tbe complainant /informant, free of cost (~i:fil~ocfldT I
,t{ilafii:fia'i qiT ~ ~ ~ ~ "1T<ft, ~ ~ ~ ;i:n;;rr Jfiz 'Q""ql q;rtft ~~
nlcfiJifrlcfidl cflT tr a'l<fi)
R.0.A.C. {3trr.3TT'.'Q'.~.}
14. Signature/ Thumb Signature of Officer in charge, Police

impression St" t '()"' I ~
~ ....... t<iff.q,1
IU \ ,."\.I ·;t::
= t.rm-'1- .• ., ~P.=;,r\
V ......
,11 ... f ...... ,, .. ,
of the complainant/
informant (~i:fiF4o4><-0 /
<t(i:l,iifctidi ,t- ~m I ~ Rank ('CJA): I (lnspedor)
<fiT ~mrr)
No. (~.); F27
15
• Date and time of dispatch to the court(~ ~ ~ .t'l" ~
~~):
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HARYANA POLICE CITIZEN SERVICES (eifi4JOJI ~ ~ · ~ )

~~~
{tml 154 i:s ~ ~ ~ ~)
Attal'l,ment ti.> item 7 of First lt1formntior1 lkport {><l!r.lT ~ ~,:- ;r; ;n:; 7 ~ } :
l'hysieal teature~. deforll!itics :md otlu'.r details ofth,• suspectlacensed: ( If lrno\rn /,,·en)
S. 'io. l):tte i Year Of Build ('il7l'l<lc) Height Compll'1ion ('{1T) ldcntifkation Mark(s) (tr~ firrr,)
(if>'.i.} lfo-tlt (;;r,:;:f fi!rfir H·.ms)
(~
/ rt}
('f\' •.=ft.}}
J 5 7
l)cformitk~ / Pcculi.aritics Hair (<l'Rf) ll:tMt(~i(~} On·,s Habit (~)

(~/~} (~
s ? ti! 11 l2 u
Latr~~UHgefl)iakd Other, (3f.'<f}

(:llT'ITJ.m;\t)
Hurn '.\la,·k (:;;;it Scrtr ('Ql'q)

S"' ;;;,. f.r~ffi1)
15 17 18 20
Th~,c !klds will be entered. only if complainnnt/inforrnant i.:h•t,> any one or more p:tl'ticular., ahoiu th,· ,u,pcctlM<:m,c<l.
(<!tr ITT ii3!'l ~ f%v- "S!Rh'r ~ f u ' ~ I ~ ~ I ~ <li .rrt # ~ ~ 7,ff 3m{ 3{,Uqi ~1-0 @ &)
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188
Ireo Private Limited

Notes formi.na Dart of the financiil!S statements
5 Loans (at amorti,;;ed costl

A.sat As at
3,!, Manh, 201~ ....3.1 March. 2018
Rupees Rupoes
current
t.oan to bod'{ corporate*
Uns0cured~ c:ons1dE>rPd gnor1
7 Other assets
Non-current Current
As at As at .A.sat As at
31 March, 2019 31 March, 2018 31 Ma~ch, 2019 31 March, 2018
Rupees Rupees Rupees · · · · Rupees
a. Advances for purchase of land

Unsecured, considered good 29.95 2:), 9~;
Doubtful 25.00 i;.00
- .... 54,95''' 104.95
Less; Provis!on for doubtful adva:1ces ,,,,_,. ...____,.,__,..,__,.. ··-···-·- ;.25.00 ··---·· .75.00'
___________2_9_.9_5__ _ 29.95
t,, Adv,mces for purchase of development
rights
Unsectlr':d, ccnsKlwed good (refer note (:';
bek7w) 6,166,80 5,185.73
Doubtful - - - - - - - - · · · · 3,73V.'l4 ........_ •.,..... 4 307.94
10,899.74 9,.493.67
;4,732.94\ ,4,307.94;
'6,166.80 - - -5,185.73
C, Capital advances
Unsecumd, considered go0d ~().),~ 27LJ.2
DOUbt!ul ol.O:i
(I2.29 271.J.l
62.05
,._, __ ,,_,_w,w-wn, ~ ~-~~-~,
Security deposits
1 _ 271.12- .....
d.
Unsccurt'!d, considcrt,.:d gocd 44.83 44.BJ
44,83 44.83
Advam:es recoverable
Unsecured, consider~d good 4,026,2$ 5,410.61:l
Doublfu; 19.97 19.97
4,046,22 5,430.64
,19.971 , 19.97
_4,026.25 ,,_ . __ S,410.68 ..
f. Other advances
{Unsecured, considered good}
Adv~ncc r:tguinst Jolnl dcvcloprnent 5,055.00 S,OU0,00
agreemem
Prepald e;'(pcnseg 4,894.90 l. .411.90
Balance w11f1 2,tatut0ry .awU1orf~-ics ~r<.;f<:t 2,344.98 .L,43U.30
note (l1) belcwi)
Compensacon recoverable (refer note 42) 299.29
9,149.49 '•
Total (a+b+c+<H•e+t}
Notes:
(i) The Company has entered tnt,:) arrangcm,.:::nts; with its vado~.•s special purpose vehicles (SPVS} for development of reat eslate
;m;Jc~ts. ~u,suart to these 0m:1r,gcm0nts, Cmnpany ,,m; provioca lntere.st free ,1tlvances to these SPVs for acquiring
dcve!oomcnt rights In 1c1nd parcels to be purchased through these SPVs. The SPVs h,w,, further advanced a sum of Rs.
7,260J;l4 {:'/l March, 2.01.S: Rs, 7,282.01) net of amount wrim,n off Rs, 1,0:31..28 {31 March, 2.018: Rs. 1,031.28) to vario•.Js
pHrti&s ro, p:.::-chase of l<.mct pan..:ets. lh~ tt1lrO pentks. to -1Jnorn rT\onk~":, have been ac,1anc:cd are yet to 1di;2rtJfy the :Qrgct
land µarc.els. Out cf the aforesi.il\; ndvances 1 n,anagc:ment, bQsed on !ts assessment1 hc1s provided. a sum of Rs. 4 1757 ,94 (3 .l
Man::h 1 2018~ Rs. 4~382,94) as doubtful advance r;nd for the rcmo:Jlntng mr1ount it is confident /.:Jf ult:irnntc
actiustrnenth'eccverv orthe~e ba!unces and ha!'1 treated trier,; as \lOCct cf recoverv.
(ii) Balance with statutory auti1oritlcs rnciuctes Rs, 150,00 (Jl March, 2018: Rs, 150.00) p;fd ,i,,
;in advance service :ax hvbility,
Managerner:t is hopeful that the sa,c ,,mount woc;!d be ar:;ustcd wqatn,it future t.ix liability and accordingly no provision has
been made for thr, same.
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189
h•,1,•n Pdv~H{" Limited

\v11·, (n fin:rnei,tt stntt,mrnts for rllc n,1r cmk<l :'1',rdi JI, JO I~
C:1•rtrnf
M11rch Jl, 2018 'v!HcttJ l, 2\H 7
_____.f...R=''·) .•• 'rt,._)_
!.nan \<) hotly ~01·1wrate*
tin~i.: 1.:urcd, c1msidcrc-d good
:'ion-rnntn! Curn,<1E
:-.lal'd! Jl. 2(1JS Mardi Jl, 2017 ~larch Ji, :!(l!H \lar~h :ll. 20!7
_ _ _ _ _......,(..c.Rc.'·cc)_ _ _ _ _...
(l_{,_.)'----·-----'(Rs.) ._ (R,.) .
A<lv,mees for pnrdw,,· ofl:wd

l!nsi.:i.:un.:& c:or..:dt.k(t'd.1,t.1.'od 29.95 3 IA3
D,whtfol 75.UO 75.0(l
lU6AJ !04.95
(75J)f)) (75.00)
,.1, :. __________________'""'________ 29;._'i__S_______:_;_I_,q
i\dvmH-~es- for pi, rdu1~e 1,f dt:vclnpnH.•nt rip.ht~
Un~ccurcd ,onsid~rcd gnod !rd'i:r n<.Jtc (i;, bd\lw 1 5.tss.n
!)uubtliil ,1.3()79,1
. 9,49J.67
f4.J 07 ,94) ,,-,-,>~-•-'•M \ •t.352."):t')"
5- l :i5. 73 .,,_, 1.J.307A~-
C~t•it~I :ulvance:~
l, Jns,;,~11n!d~ .:,1n'!'ddcred grKi(t
Seturity dcposHs
Uns..:cun.:d. con:'i\dt!rt:d guod
l,;11;:-e,;ured~ C<Jn~1.c!~r<:d go•8,i

t)-,)uhtHil
(Ll
Oth<'r ;:dv:inc~~
Un::;<..'t-tire~i, <.::on~idt:n.:d ;J011d
/\tl\;..tnt<~ :.igain$tj(1 1·n\ d~wd1~pm"·nt :1gtt:-l'1m:nt 51000.GU
Prepaid :.::qx:ns,., l.41 l.')l.\
B~!l;rnc<~ with SUHutory :-HJthoril1cs (r"f~r not.: t ii ·1 h::k.1w} 2,438.30 l, 17 !. 7q

C1..1n1peast1tinn rt'covcrnhle (rcf~r note 4 t) 199.29 299,JO
'>. !49 .,;:1.:,9-----:,..c.:,"'2c:3,-;_,':".io,-,
.\u-tt_•:~:
ti) Th<: CnmpaH)-' h~c=; cntNGd mto arrangement:,: \\·'Jh ih VdrilH1s ,sp('.Cta1 purpos:: ,,,d'1icks: (SPV~) hK development of real ~st.ntc proJ1.:.\:t.., Pur.smint tn
thc:,;c nrr\mgcmcn.1'.\, Compnny hns. provak<l :ntcn:~;t free ~idvan1..c:-- tn Htt.:}!i.:. ~'H'.,Vs fbr acqmnng: (kvdopmt'.nt righ1!'> rn land p:JfCt,!!S t,) be purcha:-.c-d
thrrni1~h H1c~0 ~H~'-ls. The SPV5 hav¢ furthc-r advarii:cd a sun1 ,-;;r R::-:. 7,'l8:JH tMnrGh 3L. 20!7 R:-:, SJ-{95J}6) m:t \'11' amount wnttcn off Rs
1:03 l ,28 (~1nrch :t 1, :20 I 7 Rs. l )}3 l .28} lo varmus panit:~ fr,r rurch:,ts\~ of' hind p~ln:d." The third µon~-:.,:, ttr whom mnnle~ hav~ rk."\-'.n ndv~uh:~d
an; yet t() idcntil\: !he ttffg,.;t !amt pnn.:i:b: Cul \,lf tht: ,1fore~aid advanc,~::;, managem:.:m,. ba5t..:d ~;n ks a~:•cssm<:nt, h«s provfdc<l ~, sum of Rs
,i3S2,94 (ri.,fnxh 3 l 1 2017 rt-,_ 4/127 .9•l) as dm1tJ1Hil ;1d,·.:int;v ;1nU for tl1..: ({,~1n;1in~ng. m,1<1m1l lt is <::onfrdcnt of uHimate a<lju~tmctHirecuvcr) u!
1he.~c halttnce$' :md has tn:~ilet..f them n~::, good of r1..:ro\•Cfy.
{JiJ Hal:rncc with ,tmnwry l\11tl1(iri\!t'.c foclude., fb ,5t1.<)!! (!vforch ; ! , Wl7: Rs lSfl G(l) p:iid as a11 ,,(lvanci: $~rYic-: mx liability, Mmingcmcnt is
lwpefill lhat th~ ~aid amn\lnt \Vot1h.1 hi.,~ ,1qJu~r,:d ;t;;Mnst fotun: rr~.;,: li:ib-rtiry ::1nd ac\.~nrdingl.v no prnv1~hhi bas i)tt,'il ma<le ior Hw, s:1mc
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190
Ireo Victory Va!!ev Private J..lmited

Notes formino oart of the fina.ndal statern.en.~t~s____
As <l•t As at
31 M,trch, 2019 31 Mdr<:h, 201.S
~-'•'µ"'"=-'~'-,~~,-,~vm,<, « ~--~-=-•• ~-"-'"
Rupees Rupees
14 Short-term loans and advances
(Unsecured, considered good)
Adv:r'l<:Oc: for pur'ch,::is.::: of \::::i.nd !;;ff,({ deve!onrr.en'..' nghts

r< Re:otccl portie~s ( refer 6t · }:)il'.; 4')t>1:1'.) ,1
J;. 5cci,rH,y deposit::5 10} /'2/){li~, 14, '-){)/_.~)(;(;
c 1\d'f<J!H)t!:S r<,;:::<;oven::ibl~;; wi kind
1. Reiati::id phrt:ies 1,81:J
Others
d. Other loans ano ::.i(1V1Htu:::1
!\dv.::;nc1:~ ir.C,'At&~ ::21.x (,:'1et
Prc~ald "1/,~Y:-!U,}(IJ .,·3'.~f':,
i,i f:<•1.;1nC(: 44¥4t;6/t:/ S'/ .0~30, :;,:1:;
_ '"ifi 1,990,os?___i;;_s_s'"·,_o_o"-·o=,s"'3c.·;i_i _·
15 Other current assets
l,'}te:··i}St accruec ;)rr

Un,~)t:ied revenue
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191
urrvni
,1!, 2,01◊ ;\/!;Irf(J
()ursrand.ing i't.n· g rH:dod t'¼rctding s,h. tno~dh~,; t'nHn tha,~ tbih;! dH')
dttt:' ffi'tHl p:t.ffHf.~nt
f .·urn.'nt
Vbn·h .'.: ..20!8 :\:lard; .l'
( IIIT\'!11
J(:;..,,'J\tt'd un
:1'.bi!kd rt:\\:ntk~
Tot;tl
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192
Project Skyon
Total saleable area of the project 16,38,434 Verified fr()m building plan
Area sold as at 31 March, 2019 11,00,418 Vi:::rified from booking register
Balnnce unsold area '.i,38,016
Percentage of unsold area to total area 32.84
Tota! input before reversal 26,913,46,219 N·lO'.:i
Reversal required for Sl<yon 8,86,09,968
Input reversed 8,25,00, 000
Balarn.:e input in books 18, 73,46,219
(61,09,%8) lqnorcd
revc>rsal as per electronic cn:Jdit ledger 36855580 DRC 4

45644420 DRC 4
82500000
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193
Ireo Private Llmlted

CIN No.: U701010l2004PTC1251.63
aafance ShMt ai. at 31 March, 2019
As at Asat
ASSETS
3:lc. Marcll, 201.S
Rupees · •·31· · · Mnrch.
iiuvees2018,
1 Non-current assets
(a) ?moertv, oiar.t arc co~ioment L66i1.4G 2,302 64
lb) Car;it;,il work·ln·•oroqross 2.76c.95 2.79).47
k} lntancible assets 11.11
fdJ ;:inanc1al assels
(t) Investments 5 \.?8:'32 Ll92 88
Ch) Other ftnanclal 1'!i!,cls t;> 9CJ\3 90.63
(el Other non currer.'t assets 7 5(i.24 271.12.
m Deferred tax as,;ets ( nctl il ···•·····JJ,90.Ji..
S,8$6:i'fo. 14,652..16
i current assets
un Pro iects iriorocress 40G,14B.51 348,()49.80
ib) F;r,ancia! zisscts
0) Loans '1,0U. 78 2.844,79
(;L node rcc.-e;vablc::; 9ll.98 400.29
(iii) Cash and c,,sh ecuivalents 10 ')1H),7J 797.94
/ivl Other bani,; billance.s 10 4,003.44 6,891.09
f v} Other fm.arciat assets 12 4.633.:n l1,25L68
fc,) i.nccrnc tax asset~~ {nf!t of provisions) ;;, !.992.46 1,754.27
(dl o:rer current aHsets 7 2J.H&2.oo_ . tlLR?Q,§8
444,693:,23 391.S:t0.53
Tomi assets
EOUITY AND UABIL1n1:s

1 Eauitv
ta, '.:'.{wit:~' ;1harc- c:ro:tJ)t 13 J:i ..3'12.58 35,34:l.58
ro} Other cquitv 14 105.417.84 · ... 9 570.75
(70.07!i,l6 l 44,913,33
2 Non-current liabilities
ta) Flmm:::ial Uabihtfes
( ll Lonq term bo rrowinos 4.\. 172.0€ t,J.909.J.l
(i>l Provisions ... . ti27,2.L 445,71
42.19-1),32 64,:,ss.oz
3 Current liabilities
fa) FH"Wt'JCia! LHlbl\iUC$
fn Short term lx>rrowinc-:·, ll.''., \47.67
Cil Trade oavables
T0t;d outstanding du~ to rnicrc
cntcroriscs and small enterorises
Totid out+;tandmg due to cred,tors other 19,071.15
!'t1;:.:n mKrn enterpn~--;.es and scntd!
enternrl~g
{iii/' Other financial hotiiities HJ t66,2,39,tH 1.14,790.83
():her current liab1ht"iP.:-;. 19 158.6',J•t.t.',J ,1q.nf..94
Prcvis!on5 '/.0 17 4J9.36 ..957.1,
478.4:2s,77 297,194.34
...... """""' ..,_
Total !ia bilities 520,61.5.09 Jt1.1,s4s.3,;
Total equity and liabilities 1§!',~~~,-s:i
For$. N. Dhawnn & COL.LP For and on behalf of tne Board of Directors of
Chart~;r~c: Accountants lreo P'riv;;tte Lim~ted
F!m1 Registration No: OO(iOSON/NS0004S
~/
-~N
~hJain Narosh Gupta 6h1>r>esh Oam;al
Purtr'.\:?r' Director Director
Membership No.: 087701 DtN: 01057032 DIN: '.l/Vi'.10590
Pi~(,.t; Gur9at::1
0~1t(~: 14 Novt:'1'10Cr, 2019
l I \
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194
lreo Private Limited

CIN No,: U701010l:2004PTC125.1.63
Statement or profit and loss for the year ended 31 March, 2019
... Amount in Rs. <.t.alih. unless. otherwise stated,
Note Year ended Year ended

no. 31 March, 201.9 31 March, 2018
· · Rupe0s · Rupees
lncome
Revenue from operatlom; 21
IL Other income ?.2
III, Total income
IV, Expenses
Decreas,:j(ir:crease) in inventoiic5 23 9,718.22 ( tC,822.94)
Cost of aovelopmcnt rights acquired 30.00 8.00
Mater'ial cost and contractor expense:;. 5,728.23 ;:,720.20
Employee benefits expense 24 3,7!.8.62 S,087.20
Depredation and amort!,atlon expense 2.5 706.44 930. 73
Finance costs 26 43,:376.69 3(,,040.69
Other uxpensos 27 i4.445.27 9,897.20
Total expenses ··-····-··-·- 81,.723.47 ?.~1 861.0S
v. (Loss) before exceptional items and tax (lll- IV} {30,598.32}
V1. Exceptionol ,terns (see note 45) (14,21i8.9'.i)
VI!. (Loss} before tax (44,887.27)
VII!. Tax expenses

Current tax
Add: MAT credit Wtilization
Pefcrn::d tax expensc/(credit) 7,990.3} (10,829. 79,\
Tax adjustments 27.39
Net current tax expense $,017.70
x. Other comprehensive, income
Other comprehensive income/(loss) net off

taxes not to be reclassified to profit or loss
in sub.~e-oucnt, oeriodt:.!
Rc~n-1ca!:luremcnt gains on definerl benefit pl~ns (.SG.86)
Income tax efftH.1 19.08
Other comprehensive Income for the year, net oft.ix (37 ..fs}
Total cnmprehensive loss for the year, net ot tax . {34,9,94.56 J
Xl. Earnings per equity share : 28

Nominal value per' equity :;hare Ri.uo (previous ye~r r,s.10;
BLJsic (16.44) (9 64;
DHuted (16.44) (9 64,
The accompanyin!'.] notes ilfO an ,m:e9rc1I part oft.he ftn;:,nci<>I $t,,tements.
As per our repor, cf even d<lte
for s. N, O!rnwan &. CO LL? For and on behalf of the Board of Directors of
Chartereu Accountants Ireo Private limited
.,..
Firm R.eaistration No: 000050N/NS0004:i
~~~nPartner
Naresh Gupta
Director
Bhupe:,h e.ansal
Dlre<:."t•Jr
Memtierstlio Nii.: 087101 DIN: 0105/032 DIN: 06400590
, ,,,,1':~,-~-"'·,r··~t/
J.tl!lliarat A1garwal
Chk? Firvmdai C..fficer
Place: Guraaon
Date: 14 November,
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195
fn:o Pr·h-'<Ht. Liinitt.'-f.l

llnfon,i, Sheet n, :it Ma.-ch JI, 1(\!~
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Directorate of Town & Country Planning, Haryana

SCONo. 71~75. Sector-l7C, Chandigarh, Website: tcpharyann.gov.in
Phone: 0172-2549349; email: tcpharyana3i~i)gmail.com
============·=·- ~ . ,._.« ==
ORDE.RS
The orders E"arlier issued vide endsL No. 11353-11.145 dated 29/06/2015 l·«,s
bE·en further deliberated upon and reconsidered. It has been 0bserwd that it m,iy not be
appropriate to catcgorisP a lkenced project to be in violation of section 7(i) of flMyanc1
Development and Regufahon of Urban Are,1s Act, 1975, (,,nlv on acnHt.nt 1.if the marketing/
devdoprncnt b~:ing tmdcrtak(!n by a third party other than the original 1..kvdoper providl·d
the licencee submits its compliances in accordance with the policy parilmct<:rs dahxt
18.02.2015.
Accordingly, the orders earlier issued v1de ('mist. \Jo. 11333-!1345 dated
29/06/2015 are hereby withdrawn. Howevet, it shall be imperative to recover adi.ninistrative
charges in all such cases coming to the notice of the Department where such "Change in
Beneficial Interest" has taken place, either bef.ore or after 18Jl2.2015, ,vithout obtaining pnor
permission of the DGTCP, He
Sd/·
(Arnn Kumar Gupta)
Dated: 31-03-2016 l hrector General,
Place: Chandigarh l'mvn ,rnd (\mntry Planning,
t-{ur.yanLt, ('hl.tr·it!ig<1rl1.
Endst. No. PF-51A/2016/ 6583-6590 Dated: 01/()4/2016
A copy is forwarded to following for mformatton ,iml n,:,css,uy ,i,ction: •

I. Senior Town Planner (M), f Iaryana, Chandigarh.
2. Senior Town Planner, Gurgaon/ Fandabad/ Rohtak/ l\,rchk.ula/ His,u.
3. Senior Town Flanner(E&V), Haryi\na, Chandigarh.
4. All District Town Planners of the State.
:J. AH District Town Planners (HQ).
6. All Assistant 'T(rwn Planners (HQ).
7. Accotmts Officer, 0/ o DGrai, l faryana, Chandigarh
8. Website Administrator with the request to host the orders <in Dc•partnwntal wvbsitt'
for information of geni;iral public/ ckvdopers.
SrV-
(Rajcsh Kaoshik)
Assistant To,vn Pl,mner (HQ)
Directorni:t' Town & Country Planning
l foryana, Cl1M1digarh
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To
The Director,
Town & Country Planning,
Haryana, Chandigarh.
Subject: Application for allowing change in developer, assignrtj£.:nt of JoJnt

Development Rights and/ or Marketing Rights to IREO Grae Realtech Pvt
ltd in respect of Group Housing Colony area measuring 31, 5125 acres al
licence no. 5 of 2013 dated 21.02.2013 {LC No 2456).
Dear Sir,
1\s per policy dated 18.2.2015, we are submitting herewith request fo, gran .ing perrrn~,10 1•
for change in developer, assignment '
of Joint Development Rights and I or Mr1r~eting Right\
, • I
111 favor of IREO Grace ~eaitech Pvt Ltd having its Regd. Office: · 304, Krnchan House:
Kari.lmpura Commerc1,il Complex, New Delhi 110015, in respect of licenceqno. 5 of 2015
dated 21.02.2013 granted to Prcc1,,on Realtors Private Limited for s,,tting ,.J/J '.)f ;i G,u,,o
1
,ousing Colony on area measuring 37 5125 acres 1n Sector-67,\, village Dhi1naspur, 'E1 hs i
and District Gurgaor /
The details of land measuring 37.512.5 acres are fu 11y described in •;ch,d~le 1 dttoebe l
herewith. j
I
\/v'e are enclosing herewith a No Ob1ection Certification (NOC) of oui' com~any and other
• •I
land owning companies, Consent letters frnm iREO Grace Realtecr Anvate L1m1wc1
I
t1longwith undertakings and other relevant documents for your informatii,Jn and further
action please,
It is submitted that IREO Grace Reatcecn Pvt Ltd has ,,r1 expert technical tearrd,inu :,ctve goou
financial capacity for developing the Project Proponent. Thus we are develo~ing the proJf.,ct
over above mentioned land with IREO Grace Rea!tech Pvt Ltd.
'
amo,mt reqv'.r(:(1 on account of a~rninistr~t1ve Chorp,el' h,1~ bee1: µ,.HJ
rh;:it the 40% of total
bv us through e-payment hnk ava1,able on departments website. The cop of E-Payment
receipt of Rs. 1,54,36,400 (Rs, One Crore Fifty Four Lakh, Thirty Six Tho sand and Four
Hundred Only) Transaction No. TOWNIOC3000013126, dated ll.Cl2.20 and GR No,
ON36601902111057 is ;;ittached nerewith for your 1nforrnc1tion and
herewith,
tlminr-.-. Ai11frl''h U{t·O ( ;1mnw;, ,\u:tlYlCW l>r1'.-\.'. 11,.:c, (~11), l.,._1,1\f Cih1r:,;iz L,\h::~-; ,\,, i{,~--i:;d ~,Hn,if•,r:H'n
En~a;l P.t~J.:,d..\!J.t.,n:1;)L\~U2'.,£,f.1:!.n~uL~:.l!!'.J; ('lN ti U7~JllJ 1/Dl,2007P-!'C: 5-:,i<H
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It is therefore requested to grant permission for change in developer, a~sigt rnent o+ Joint
Development Rights and/ or Marketing Rights in favour of if{EO Grace Rea\t,:c Pv~ _td
Thanking you.
Yours foithfvlly,
For Precision Realtors Pvt. Ltd.
',
r-,~.'':i/:-"-~✓ _ , •• ~ \
. .\ \0~'/2J~,: .
.,.....,,·l·:~- '
(Abba I Singh Rawat}
Authorised Signatory
Encl:•
1. Schedule-1
2. NOC from Precision Realtors Pvt Ltd, Glob:31 Estares, Blue Plane: Infra :eve,cpers ;,.,,
Ltd., Madeira Conb1,,1ild Pvt. Ltd.
3. Consent letter frorn IHEO Grace R.ealtech Private Lirnirnd
4. Undertaking from Precision Realtors Private Limited
5. Undertaking from IREO Grace Realtech Private Limited
6. He solutions of Companies
IRE() Came,,,, Arctw,cw Dnvc """ <..nv, ,,,Ml

hn~ul·
u,~,,, :.s:•:c,,•"" lb,.J
(;,.,r.,;tr:"" , l ::u ,,
('TN1it'""n!(i{q)t ','.qn,,PlCl"-l''')
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. t P•partmlW'lt r.it Town & Couniry Vl,v1,1,1\<;

) , GMWllJt1•1tf 41 H*,Y'1f1,'l
(E,Paymant Receipt!
;,.;C;..;a;;.se;_,;.:TY;;.P.,:.O_ _ _ _ _ _i.;L::;l:;::C&::,:n.:,:C:.::6:.__ _ _ _~+.:;.;.,.--_;:.;.....,_ _ _ _1"c;;.;h;;,;a..n.-e:..Q!..D V9lo er

Cnargot iypa Admlrustratlv& Char es
Case l<l LC-2456 Appli<:ation IQ LC-245GA

5 OF 2013
Mobile No. 9999058774
Email id vtkas.kharab lreo.ln
{1,)Transaction No,
(2.)Tran~;ictjon Date.
tl.)GR No I rxn. No
(4.)Status SUCC8SS
(5.)Ro,;,,ivod Amovnt Dalo 11/0212019
(6)Tatnt Arnwnt 5436400.00
(7 -/Remarks Administrative charge& payable on submission of ChangEt I Dovatopor
Application
(8.)Payreont Mo<fo Online EFT/RTGS
NOTE1: This is subjected to reallz:atlon/credll or the payment to Department Account
STEPS TO VERIFY PAYMENT STATUS WITH THE HELP OF QR CODE:

1.lnstalt QR scanner app on yo\.lr mobilo,which = i be downloaded free from App Store/Play $tor
2: Once OH scanner app is H>i:talled. open the app and point it to code on the receipt.
3: The application will scan the QR code and a page will open \\ith, <Open Website>. <Open UR >.TI1,,, opt,o~ is apo
dependont.
4 Click on tl1is option. Payment stiltus Verfication page wiU open

Requirement: ,
1: User ~eeds to have a QR scanner in l1is mobile. QR scanner apps are free arnl can tie c!ownlo4ded from the App store
on your rn<>bilo , I
2: lntemei conr1ect1on on Mobilo I
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IREO PRIVATE Lll\/HTEU

Ri!gd. Office:- C-4, 1ST FLOOR, MALVIYA NAGAR,NEW DEL1H,ll{HJ17,Tndia
GSTlN Regn. Address: lreo Campus, Archview Drive, lreo City, Golf Course Exterision Road, Gurgaon •
122101, Haryana
C!N # U70101DL2004PTC125163, Emall ld- lpl@ireo.in, Phone #9'1-0124-4795000
TAX INVOICE
Customer Name: IREO GRACE REALTECH P I.TO

Customer No ; P4300
Customer GST!N; 06AADCG9136D12S
SillTo; . Invoice No: 181800011

lreo Campus, Sector 59, Near Behrampur Invoice Date : :I0.06.2017
Place of Supply: Haryana I Intra State
122101 • GURUGRAM, State Code: 06, State: Haryana India Reverse Charge : NO
·.s No.(Hs.NtsP:CX · · PARTIClJL,ARS ._QQM I QTY.! RATE ...... '.AMOUNT ____ _

1 I0000 ; Direct Salary Belng Allocation of Direct •NOS 1 f 2,659.647.00l 2,659,647.00
;.... 2I 000-0 l ~::~~/-Allocation ~f--l~di;~ct-Salary. Being

.......... !.Allocation. of lndirec_t_S_a!_ar~v._ _ __
i NOS '!-·:;··~·; 2:236:205:rxir' "Z:2i6,205.00 i
:~····?,o:L~
...-~.,,,,.-,,v~~•~=~-•--,~"""'""'~"""•••~w,,,,,
31'0000 - - ..........
•• · . - - - •',>.,.,W,
- ; ......
,,.,,,.
842.789.00
. "" -, . '' ,. ,. '-~-,--,~1
...... 41,oooo,.. . 't.}.. :.d-, ~•~"/!:.'.~.".:!.:.c:'.'.'..i.. ...... 2,439,309.09;
........ 8.H7,95o.oo,
1,144,913 00
__ 40,390,00
4o,a9o.ool
"----~•>O•,. -· ., .. ,_ .. :
R<:marks: .. COST ALLOC-Q1

Total j RUPEES NlNETYFOUR LACS FOUR THOUSAND SIX HUNDRED
......~FORTYTHREE OflJLY
PRIVArt~
For and on behalf of ~-· ..·-.
ilREO
Authorised Sign~v.y .'..·~ j I
\. ,, ·.. / ,j
Company's GSTIN - ~ ~ / ; 06AAACO664481ZS

·PAN No : AAAC06644B
Service Tax No : AAAC06544BST001
i ~ & Conditions
•Interest @ 24% P.A will be charged if the bill is not paid before due date as per service order.
Payment by Crossed Cheque or demand draft in favour of IREO PRIVATE LIMITED
All disputes subject to GURGAON jurisdiction - · ---
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IRE:O .PRIVATE LlMITED

Regd, Offke :• C-4, 1ST FLOOR, M.ALV1YA NAGAR,.N.KW DELHI,110017,Indfa
GST1N Regn. Address ; lreo Campus, Archview Drive, lreo City, Goff Course Extension Road, Gurgaon •
122101, Haryana
CIN # U70Hl1Dl2004PTC1.25iG3, Email id• ipl@ireo.in, Phone #9'1-0124-47il5000
TAX INVOICE
. Customer Name: IREO RESIDENCES CO P.LTD

Customer No: P7200
Customer GSTIN: 06AACCf3321F1Z4
·····-·--··----·······••·······--··············---····-··--··-·-----,,,,···--·-----·"'·"·---- ,,,,,,,.,,.,,,,_,__,,
BIii To : lnvoiee No: 181800012
lreo Campus, Sector 59, Near Behrampur i Invoice Date : 30.<l-6.2017
.'122101 • GURUGRAM, State Code; 06, State: Haryana lndla Place of Supply: Haryana / Intra State
Reverse Charge : NO
•Lti<:>~1.11i~Zi~9J _____ · ·-· . PARTICULARS.. . ... - iuoM: QTY~T . l<AI!L AMOUNT

·----»~.-,_,_,
1 . 0000 IBelng Allocation of Direct Salary. Being ! NOS 370,786.00 370,766.00
--· :............... -+6{.Location ofOire~~.§.O.~~r:L,... ...... '··· _ ... ·······---· ...., .........,-.
, 2: 0000 , . ____ . :· -,.--- i NOS 378.574.D0 i 378,574.00
:--;loooo --- --i--·· __ :- ,.. ··-··. ·-·i~--· ... \:._·,_ iNos ' j-.J._1.H.49s.oo~ , 11,49s_oo_
1
i _±,LQ9.QQ_ ... J.. -···.. ·········-·--· ...... · ..... :-__·... ··-···-~· .. ;NOS ., 1 412,959.00: ··---·--412,959.00'.
.! .. ~ubtotal: J. 1,279,814.00i
Service Tax Ji; 14 °/cl . .. ...... . . H9, 173.00
SBC.~0.5%! 6,399.00
KKC § 0.5 '¼i .... --·-- .•.. -· 6,399.00:
~ "'"''}
1
Remarks: COST ALLOc-cn .....
!Total
I
:06AAAC06644B1ZS
AAAC06844S
, Service Tax No : AAACO6644BST001
! Terms.?! Condition.£
lnterest@ 24,% P.A will be Chargect if tlie bi!! is not paid before due date as per service order.
Payi:nent by Crossed Cheque or demand draft in favour of JREO PRIVATE LIMITED
All disputes subject to GURGAON Jurisdiction -
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IREO PRIVATE LIIVHTED

Regd. Offic~ :- C-4, 1ST FLOOR, MALVIYA NAGA.RNE\V DELHI.110017,India
GST!N Regn. Address : lreo Campus, Arch view Drive, lreo City, Golf Course Ex·tension Road, Gurgaon -
122101, Haryana
CIN # !J70101DL2 □ 04PTC125163, Email id• ipf@irao.in, Phone #91-0124-4795000
TAX INVOICE
Customer No : P7100
CustomerGSTIN: 06AACCf3262R1Z7
Bill To : Invoice No: 181800013
lreo Campus, Sector 59, Near Behrampur : lnvoice Date : 30.06.2017
Place of Supply: Haryana J Intra State
122101 , GURUGRAM, State Code: 06, State: Haryana India Reverse Charge : r~o
l ' ••• "l , "", f""
j S No.I HSN/SAC/ PARTICULARS ... :,,....

UOMi QTY. RATE ....1 - . AMOUNT.. .
2 loooo ~-----
,,,,\"
! I l ·Nos 1 j
,__ ________
1 0000
~---'~"•,~"''"'"" ~'
""'""=~-w,w,-,., ••~""'"•"""""<•,, • ;,.,,
,NOS
~§Qi610.00 !
?.4?,?1?:_[JQ;
843,212.00
...... 145,9:38,00 ___
145,958.00:
,_460,610.00
f ,,,3[00_00_ _+-'-__ •.• ,.,,.,.,,,,,.,,,.

: 919,7!;)7.00,i ___ 919,i'9700i
4 !0000 i i:. . ~i···· ··········••·•·· ··-······
. ·--··-·· ·--~.':',!)!Ota(_:_, •.. 2,369,577.00,
::J,31,741.00
. .......11,848,00.
·•····11,848,00
!Remarks:
..... ~7-·"""'~·"- , .. """ -,~,--,ff~-,~-·"-'"•"'
i Tota! : RUPEES 'PNENTYSEIJEN Ut.CS T'.JIJENTY~!VE THOUSAI\!!) FOURTEEN 2,725,014.00
For and on behalf of;,.,-•···;:r··""·,

[REO PRIVAT ·. rrei~)\
Authorised Signato
Company's GSTIN : 06AAACOG644B·lZS

PAN No : AAAC066448
Service Tax No : AAAC06644BST001
~ ~ Conditions
Interest @24% P.A will be charged if the bill is not paid before due date as per service order
Payment by Crossed Cheque or demand draft in favour of !REO PRIVATE LIMITED
disputes subject to GURGAON jurisdiction --
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IREO PRIVATE L llVIITED

Regd. Office:• C-4, 1ST FLOOR, l\'1ALV1YA NAGAR,\!K\V DKL11I,H00l7~lndfa
GSTIN Regn. Address : lreo Campus, Archview Drive, lreo City, Golf Course Exte,1skin Road, Gurgaon •
122101, Haryana
ClN # U70101 DL2004PTC125163, Email id- ipl@ireoJn, Phone #91-0'!2,4-4795000
TAX INVOICE
Customer Name: ELITE TOWNSHIP PVT LTD

Customer No ; P7300
Customer GSTlN : 06AABCE6887H1 ZC
:6ill To ; Invoice No: 181800014
; !REO Campus Sector 59 Behrampur . Invoice Dato : :30.06.W1 o/
Place of Supply: H<1ryana I Intra State
122101 • GURUGRAM, State Code: 06, State; Haryana lndla : Reverse Charge : NO
's No.; HSNJS.I\S::... ---·-··-····· PARTICULARS --~-- , _UOM L.OTY,: _RAH: .• · AMOUNT
1__ 0000 . ..,. ... .. . _ ~:,L.?.~-- ;, . NOS :___ 1 294,52,2.00 ; .... _ 294,532.00
2 'oooo , •': .. : · ' _:· :.! ,::!_.:£;..-~----.. _No.~. i L , g~:.2_8_3:oo,i 95,683.oo_
. . 3; 0000_ ... -; 1 i- ,. (-'; :-.:,::__ .. l'.os : 1~---··-~'3::,_!;.9_(?,_~---· _ . _93,331.00;
~ j o.o.oo ' -~ ' ' ,...t. ;_...,-d.1:1 NOS i 1 1 104.373.09+···· -····-!.Q4'.~?-~.,QO..:
5.g919,o_o_,
Service Tax@; !io/~----•····---- 82,308.0Q~
SBC .-..:.
,_,,_____ _c!) . .0.5 o;,; "~----------~--,.-,.".
_...,.. «_,,..._ 2,940.001
• "'""'""'"•w••••'-""i
.... _KKC@. O.b % ......... __.,.,"........ . 2,940.00 i

I Remarks:
,.....,,.,.,,_,."_,_.,.,,., ___ " · . • ••· ,-s;
: Total i R.!J PE.ES S!.X: LACS SEVENTYS!X, THOUSAND ONE HUNDRED SEVEN
..10NLY
For and on ;1eh:,ff of

lREO PRIVATE UMlT~~- 'r; .. -~.
}-~t,, ~
: Authorised S:gn:,dt( _./ /
---~·••"·· /
Company's CSTIN
_
..., ...... ..........~... ~ /
; 06AAAC0664481ZS
PAN No : AAAC066446
Service Tax No : AAACOG644BST001
. Terms £ Conditions
! Interest@ 24% P.A will be charged if the bill is not paid before due cJate as per service order
·' Payment by Crossed Cheque or demand draft in favour of IREO PRIVATE LIMffED
· All disputes subject lo GURGAON jurisdiction -- -----·
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lREO PRIVATE LIMITED

Rcgd. Office;- C-4, 1ST FLOOR, MALYIYA NAGAR,.l'iJi:Wl)F,LHl,UUOl7,India
GSTIN Regn,, Address: lreo Campus, Archview Drive, lreo City, Goff Course Extension Road, Gurgaon •
122101, Ha.ryana
CIN # U701010L2004PTC125163, Email id- ipf@lreo.in, Phone #91·0124-4795000
TAX INVOICE
Customer Name: FAITH BUILDTECH PVT LTD

Customer No : P5100
Customer GSTIN : 06AABCF5891J12C
'-----~------··"·"""""''"'"""'""'"'"'""---------,--
BiftTo: ltnvolce No: 181800017
1
Ireo Campus, Sector 59, Near Behrampur Invoice Date ; 30.06.2017
Place of Supply: Haryana J Intra State
122101 • GURUGRAM, State Code: 06, State: Haryana India Reverse Charge : NO
I
•.•. ··1 . " .. "'"""
- S No.i HSN/SAC' --·-----·- PARTICULARS UOM QTY. i RATE-----' _, __ AMOUNT
1 !0000. : 1 ,1/1 ,, , !NOS i 1.867,209 . 00 1 J,867,209.00'
2J 0000 - ~ , .. .') ,} -~7 '7;;.c,, :~5:: .. . .•.JNQ.§.. 79,484.00; 79,484.oo;
3 iOOOO ; : , ) .: ', ~' ( ; ;,. J/L, !NOS I 1 s91;,a1.rn:>;_. s91,6s1.ooi
4_!__90QQ_"_~_,,-.,"•~,---,"'',?'L J,, r; ~ !NOS I 1 86,703.00 i -· 86,7(}3 00 !
i
--------~-Subtotal: ... L . . 2.625.077.00
_···--······----· _ Service Tax (iii 14 %J .....J _ ..... 367,510.00.
SBC tu, 0.5_,,......,.,r-
o,,;J 13.125.00
13,1?§-9.0,
Remarks:
,,,. __ , ''"""''•'"''""'"
. RUPEES THIRTY !.ACS EIGHTEEN THOUSAND EIGHT HUNDRED 3,018,1337.00
For and on bd:alf of

!REO PRIVATE "lfMtl'Et:r;:,,
<{ . i\i',
i Authorised Signatc;\\
' \\ \:- ___,,./) / )
'·'-,. 'a. ,/·,,.
Company's GSTIN ·-...:_~,•#" : 06AAAC0664461ZS
PAN No : AAAC06644B
· Service Tax No : AAAC06644BST001
Terms~ Conditions
Interest @ 24 % P.A will be charged if the bill is not paid before due date as per service order
disputes subject to GURGfa.ON jurisdiction --
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IREO PRIVATE LIMITED

Regd. Office:- C-4, 1ST FLOOR MALVlYA NAGAR,;'IEW DELHI,110017,lndfa
GSTIN Regn. Address : .lreo Campus, Archview Drive, lreo City, Goff Course Exhm::.ion Road, Gurgaon
122101, Haryana
CIN # U70101DL2004PTC125163, Email id- ip!@lreo.in, Phone#91-0124-4795000
TAX INVOICE
Customer Name: GP Realtors Pvt. Ltd,

Customer No : P3100
Customer GSTJN : 06AACCG6280B1ZY
Invoice No: 181800018
!reo Campus, Sector-59, Near Behrampur Invoice Date : 30-1)6.2017
PJace of Supply: H.1ryana I Intra State
122101 • GURGAON, State Code : OS, State: Haryana India Reverse Charge : NO
~--~···'-""'"""""""'" ,,-.~-~-•. "~-~·"'"
: UOM i QTY.!
! S No.i HSN/SACi
r··-1:aooo ., ,.___
PARTICULARS
-----------_-,-)i-Q.·i=:~_!.. 5,906,83i~o J
RATE
r-·
• AMOUNT
5,~?6,~37_:00:
.?.J 0000 > •• - i ••'--------=--------+'-----11:10_8_'~--· 237 .587.CD;

. . . f:f ·--·~··1 NOS i 1,871.759 CO ....
.i..
1.s•· ..,. i NOS
, r,., 259, 1(16:'.l0 ?:5?, 16§:90
.827,535.00.
Service Tax:Si .14 o/1 _J.158,548.00

,_..----------------------"s....B-'-c@o.5y_l ........... ~-- 41,377.00.
____ . !S.IS9 ,i.i o.s t! . 41,3n.oo 0
1Totaf RUPEES ONE CRORE THREE LACS FORTYFOUR THOUSAND ONE 10,344,185.00,
...............HUNDRED EIGHTYSIX ONLY
Company's GSTIN : 06AAAC06644B1ZS

PAN No : AAAC06644B
. Service Tax No : AAACO6644BST001
Terms~ Conditions
interest@ 24% P .A v./41! be charged if the bill is not paid before due dale as per service order
All disputes subject to GURGAON jurisdiction
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IREO PRIVATE LlMITE.D

Regd. Of.Ike:• C-4, 1ST FLOOR, MALVIYA :--IAGA.R,.:-rnw· DEL.H!,1 Ultll7,fndin
GSTIN Regn. Address : lreo Campus, Archvlew Drive, lreo City, Golf Course Extension Road, Gurgao11 •
122101, Haryana
CIN # U70101DL2004PTC125163, Email Id• ipf@ireo.in, Phone #91-0124-4795000
TAX INVOICE
Customer Name: Sunflower R.eaftech Pvt. Ltd.

' Customer No : P6200
Customer GSTIN; 07AAKCS4064P1ZP
Bi!fTo: Invoice No : 181800019
;305 3rd Floor, Kanchan House, Karampura Commercial Complex Invoice Date : :10.06.2017
Place of Supply: Haryana I fntra State
; 110015 • New Delhi, State Code ; 07, State : Delhi India Reverse Charge : NO
'""' ""'""""'""'"""~""·« ,~,,-,,,-,,,~,,

Subtotal: . g~,011.Q()
..,,,,.•Service Tax '.ii 14_o/,[, .J3,862.00
SBC a; 0.5 o/,i
.,,_,,.,, ,~___,.,_,,~"'"''".1.,.-..
496.00
. ___ KKC_"f~ C.5_%. 496.00
Total i RUPEES ONE LACS THIRTEEN THOUSAND EIGHT HUNDRED 113,871.00

. . - . ..... / SE\/ENTYONE ONLY
. , , '.. ~f,,_.r'~·~·--,""'·,,"",,
For ano on oenan ,:>f ·? .•.•."' ··,,\
/;>" . .,t,.. "''•,, _.,<:'\\''
_IREO PRIVATftf(MITE~.~~,r
.Authorised Signaf·..,,ry\
\ ....,,,,._,~pl'i
/ .~/
·;
"-... ~.,..¼.!":::.~'~,,_;.,;!'/'
• Company's GSJIN : 06AAAC06644B1ZS

PAN No :AAAC06644B
Service Tax No ; AAAC066448ST001
•~~Conditions
Interest@ 24% P.A will be charged if the bill is not paid before due date as per service order
\ Payment by Crossed Cheque or demand draft in favour of !REO PRIVATE LtMfTED
;Ail disputes subject to GlJRGAON jurisdiction
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Rcgd. Office:- C-4, !ST FLOOR MALVlVA NAGAR.NE\V DELHi,1lU01'7,india
GSTIN Regn, Address ; lreo Campus, Archview Drive, treo City, Golf Course Exter,sion ~oad, Gurgaon ,.
122101, Haryana
CIN # U70101DL2004PTC125163, Email id- ipl@ireo.in, Phone #91-0124-4795000
TAX INVOICE
Customer Name: IREO FIVERIVER PVT L TO.

Customer No ; P3900
Customer GSTIN ; 06AAKCS6739H1ZY
Bill To ; invoice No: 1a1a:00020
Village lslamnagar, Sector 3, 4, 4A, Kalka Urb:'ln Complex, lllVoice Date : 30.06.2017
Pinjore, , Place of Supply: Haryana I Intra State
134102 - Panchku!a, State Code: 06, State, Haryana India Reverse Charge ; NO
, S No. N/SACi PARTIC:~~,~,, UOM: QTY.; RATE AMOUNT

1 i 0000 ., } , , ',." : i NOS • . 1..,,.,. 47,499.00; •••. 47,499.00 •
r··2loooo . . J. _:_·,._,-~~---·. _,·_· _-': ....~,-- il',:lg_~L., ...J., . •,. ... 1,10.427,oo' 119,427.oo!
3 I0000 ,L • , .. _, _ ,. ··-·-,- .,.,.,. , . NOS 15,052:,,QQ__ ,.. ,.~. 15,052,00
1:,Q,274,00 I
SBC '.h 0,5 °;,,

' "~-.,,-~--~ ,,_,.,_w,-,v,-,w,-._,,_,_,
1,561.00
1,561.00'
IR.emarks: .,.. ,.-,.. _
; Total
,-,~™-,,_,~-,,,_.,-~,,
;,• w',A
i RUPEES THREE LACS FIFTYNINE THOUSAND E!GHTYNINE ONLy ,. 359,089.oo I
Company's GSTlN : 06AAAC06644B1ZS

,PAN No : AAAC06644B
Service Tax No : AAACO66446ST001
Terms! Conditions
Interest @24% P.A wrn be charged lf the biH is not paid before due date as per service order
Payment by Crossed Cheque or demand draft ,n favour of IREO PRIVATE LIMITED
All disputes SL,bject to GURG!,ON jurisdiction ·
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Regd. OHlcc :- {>4, 1ST .FLOOR, lWALVIYA NAGAH.,:>n:·w Dii:LHY,UU(}l 7,India
GSTIN Regn. Address: !reo Campus, Archvfew Drive, lreo City, Golf Course Extension Road, Gurgaon •
122·101, Haryana
C!N # U70101DL2004PTC125163, Emaif id• lp!@!reo.Jn, Phone #91~() 1 ?.4-4795000
TAX INVOICE
Customer Name: lREO WATERFRONT PVT. LTD.

Customer No : ?3500
Customer GSTIN : 03MCCV2433R1ZS
• Bill To : Invoice No: 131800021
SCO 1!M7 3rd Floor, Fortune Chamber, Feroze Gandhi Market Invoice Date : 30.06.2017
1Place of Supply: Haryana I Intra State
141001 • Ludhiana, State Code: 03, State: Punjab India · Reverse Charge : NO
~ s No.I HSN/SAC l PARTICULARS ······-··t-··':JOM : QTY.. , • RATE AMOUNT

l 110000 Jt::.,. :~qs 2sa.3s1.oo. . 2sa,3s1.oo
L. ,2_;,:0000.. ! .
·1 ' ~ / '"'
NOS 1 2.92,271.00I ,..,W?,27).00
310000 NOS 81,866.00 . 81,866.00
NOS 220,643.00 •
"[
763,131.00 j
3,815.oo:
!06,838.00 i
3,815.00.
RUPEES EIGHT LACS SEVENTYSEVEN THOUSAND FIVE HUNDRED 877,599.00 .

!NINETYNlNE ONLY
Company's ~ST!N . 06AAAC06644B1ZS

PAN No AAAC066448
Servi.ce Tax: No : AAACO6644BST001
Terms & Conditions
lnterest@24% P.A wm be charged if 1!1e bill is not paid before due date as per i;ervice order.
All disputes subject to GURGAON jurisdiction --
&
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226

Regd. Office:- C-4, 1ST .FLOOR, MAINlYA NAGAR,NEW ffFT.H!,110017,hldia
GST!N Regn. Address : lreo Campus, Archview Drive, lreo City, Gorf Course Elrtension Road, Gurgaon •
1.22101, Haryana
CIN # U70101 DL2004PTC125163. Email id• ipl@!reoJn, Phone #91-0124-4795000
TAX INVOICE
Customer Name: PRAVESH PROMOTERS P l TD.

Customer No : P4200
Customer GST!N ; Unregistered
BiflTo: Invoice No: 13181)0022
A-111st Floor, Neeti Bagh Invoice Date : 30.06.2017
Place of Supply: Maryana / Intra State
110049 • New Delhi, State Code: IJ7, State: Delhi India Reverse Char!;1e : NO
,.S No. 1_HSN/SAC -· ,,..,, U_O_M / 9TI:. ,RATE,.,,.J . , ,,,AMOUNT ..

1, 0000 . ,NOS __ i .. 1 2,94M0 1.•.. 2,_94_6:00.
2;0000 ' ~ . ~•._1__,,,,,' 3.G63_oo: ........ . 3,66,~.G0
:3, 0000 934.00; 834,00
4\0000 :i995:29i
11,538.00_
1,615.00
' ,.,
58.00'
,.. -.~· ~"'-")
58.00 __
For and on behaJ-:i.f -,

IREO PRIVATE{UMITEJ:~)
,_ '>,.,, .,/cJ;.l
Authorised Signak;cy•,.----✓ ,. -
~"'';-.. ~,., ,...,,~,,,,,.,¥
Company's GSTIN ; 06AAACO6644B1ZS

PAN No ; AAAC066448
Service Tax No ; AAACO66448ST001
.Terms~ Conditions
lnterest@ 24% PA will be charged if the bill is not paid before due date as per service order.
•Payment by Crossed Cheque or dernar;d draft in favour of IREO PRIVATE LIMITED
Ali disputes subject to GURGAON jurisdiction
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227

RegdA)fficl', :• C-4, 1ST FLOOR, MALV1YA NAGAR,NEV'i .DEl,fH,1101117,India
GSTIN Regn. Address : lreo Campus. Archview Drive, lreo City, Golf Course Extension Road, Gurgaon -
122101, Haryana
GIN# U70101Dl2004PTC125163, Email fd- lpl@ireo,in, Phone #91-0124-4795000
TAX INVOICE
'Customer Name: PUMA REALTORS PVT. LTD.

Customer No : P3800
: Customer GSTfN: 03AAOCP6870D1ZM
!swro: : Invoice No: '!81800023
/ Village SambhalKi, 1st and 2nd Floor, Sector 99, Sas Nagar !Invoice Date : 30.1)6.2017
'I Place of Supply: Haryanu / Intra State
160062 • Punjab, State Code: 03, State; Punjab India IReverse Charge : NO
I
/ uOMj QTY.! ·· RATE__L . . AMOUNT
" ._.,,,,,,l :·-··
i§...,!;-1.5!:J, HSN/SAC, PARnc-uLA-Rs-·
l 1Ioooo · .,L,?,''·J , , !NOS : 1 l 108403,00/ JOS,403.00~
,,,~ i 0000 ,· > J ····~ NOS i 1 r-219,008.00l .. _219.008.00 1
j '1 .., f . "'" . ~' ' \
3 I0000 ~~-', c / .. t ?, ) "'i; ! NOS t 1 · 34,351.00 i·-··--··-34,35L00'
I
4 :0000
,
. /NOs,.L_1 I ·238,899.ooi .?.3(-l.~9s.og;
Subtotal: , , 600,~€}1QQ•
"'""_" _____,"i
........ tM,092.00,
'
I
3,004.00
"''"'' ,,.-t ,,,,
... ).OOM01
!Remarks:
; Total ··\RUPEES SIX LACSNf.NETY THOUSAND.SEVEN HUNDRED SIXTYO.NE---·-· 690,761.00
·oNLY
Company's GSTIN : 06AMCO6644B1ZS

PAN No : AAAC06644B
! Service Tax No ; AAAC06644BST001
•Terms ~ Conditions
Interest@ 24% P.A will be ct1arged if the bili is not paid before due date as per ser.iice order
1'\ll disputes subject lo GURGAON jurisdictfon --
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228

Regd. Office :- (:.4, 1ST 'FLOOILMALVlYA NA(;AR,NI(\V DELHI, i 100,17,,lu dia
GST!N Regn. Address: lreo Campus, Archvtew Drlve, lreo City, Golf Course Exte,1slcn Road, Gurgaon •
122101, Haryana
CIN # U70101DL2004PTC125163, Ematl id• ipl@lreo.!n, ?hone #91-0124-4795000
TAX INVOICE
Customer Name: G P Realtors Pvt Ltd.

Customer No : P3100
Customer GSTIN; 06AACCG6280B1ZV
.Bill To; Invoice No: 181800024
lreo Campus, Sector-59, Near Behrampur Invoice Date : 30.06.2017
Place of Supply: Haryana / Intra State
122101 • GURGAON, State Code; 06, State: Haryana India Reverse Charge : NO
• S No.i HSN/SAC i PARTICULARS ------: UOM • QTY. i ry,,Jg ___., AMOUNT

1 iOOOO ··-·-·- , :. ... ,: , I ······r---iN_O_S .•.••• i5,906,8~1700'"';_ _ ..;.;;.......:c;.._
~o....o_o_o_ ____..,__;, .•. '•·-•--'·~('~-._..r_·_......,.._, ·• i) i i Nos_ .. 1 \ 237,§~Z:90 .

,, .,M;,,t,· :,, .'t ~ ,' /,·-t(,,,' _r_•·_•···..·,·,-,_~,_\,1',· ,' ,·,, }1L.. ' 1NOS: i ..J 1,87'1,n)9 00:
J,871,759,00.
3_·_00_0_0_ _
4;0000 , . ,.. _,, r . , , , {: ,:sd1l NOS I
- - ~ - - · ' > ~'"v,VA'" ''
1 ! 259,166.00
',~,;,e,,--,~«•••-<•~,,.,<-,••"•• •• • '<••· • ,nO ~
259,166.00,
f:l,?75,349.00,.
'Remarks: SAL ALLOCATIO~Q1
iTotal i RUPEES EIGHTYTWO LACS SEVENTYFIVE THOUSAND THREE 8,275,349.00
............J HUN.OREO_ FORTYNlNE ONLY
For ar1d on behalf of
IREO PRIVATE
J.\uthorised Signator\,
tJfd:~.fa,
.•(::-:··?>,
\ ., •'· ··· f,6,;

', ·, ....' ~7
Company's GSTIN , : 06AAAC0664481ZS
PAN No : AAACO66448
Service Tax No : AAACO6644BST001
'Terms & Conditions
Interest@ 24°/o P.A will be charged if the bill is not paid before due date as per service order
· Payment by Crossed Cheque or demand draft in favour of IREO PRIVATE LIMITED
A!I disputes subject to GURGAON jurisdiction -- , ....., ........._...
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229
EnH~rtJ Dale Postmg [)~tt;: Dncwnem CnmpJny & (J.'L A,cou. G 'L /u'..,~OlH C,)st (.\~n1-;· Ccs1 C.:n1~r Rtfr,:,ne:t.>. Debi: Amn,Jrredit Amcl!)ebl! AmoJCredit AmclAmoum in loci Curr
1Ji-(;S»:ZOi9 )J-03-20!9 SA !RH.: PVT l4.l672 CGST REVFRSA! l S,) D,\ YS UST "iOV' 32-!78995 CJI 32-.178995 0 3).:1)8~995
'"'0-U5-1n i 91 3 J-tl3 .?fl! 9ISA
4
iHSU PVT l ,i:;;;741JG:,T REVLRSAL DAYS l(iS I ~;uv ( l f,)3(H);J7 ,JI t.130047 OI l,14,.30,(J:17
2(lAC5-.?C,lt)I 3i ,fJ3-20i9JSA !Rl'Cl l'VT l·lY,73 ISGST RF\TRSAL I :~o DAYS IGST Ml\' I 32478995 (if 3:.J7S9')5 01 3,24,78,9:)5
2U~U5-J019) 31--03-10 i <1fSA JREO PV !43674llGST REV1,RSAL 180 D,\ YS !vbr't1 723798 ~JI 1123798 GI , 7.23,7%
20-(J5,-]019J J ( .{)J<20i 9ISA !RH) PVT l-1367JISGST REVERS;\L iSODAYS Mmi1 !98319,JO (;f l 9S3 l 9i)(} Ol 1,98,31,900
20-GS<Wl 91 3 Hll-2tll 9fSA !!ff() PVT l4:10721CGSTREVERSAL l~ODAYS :'>farl1 l983l.900 fl l~1S31900 OI l,93,31,90C
11,77,75,635
-
.r
jJ
I
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230
Pos1ing Date Comp,lll'., \Gil.Aecom Ci!Sl Crntc! Cost Ccrnu .\m0unt in local Cu\ b1:r Jl) l: ;er >:«me 'I ax C ,1,k Shon kxt Gruuprng
3 l -/D-20 l 9 lREO R FSl CGST REVERS.Al l 80 DAYS .i.03.68J 98.00 GGOI Fl30 ATUL KUM,\ R Sl?<G!· hcing <.:;!~U,gstlg:;, ad1uitmcnt entrie$ Balance,, ith sta1nM')' aath/lrities
3 l-03-2019 lREO RES! SGST REVERSAL l 80 DAYS UU 24.016 O<J GOO! Fl30 A I UL KU!'vlJ\R SlN<il being cgsttsgstngst ad1u,tmrnt entries Bahmcc with statutory aathoriiks
3 l-OJ-20!9 lREO RESI lGST REVERSAL J 80 DAYS l .73.744 00 GGO! Fl30 ATUL Kl:MAR SING! being cgst;sg,t,ig.5t ud:u;!mcnt emrics Balance with s1atutory authorities
31-/l3-20l9 IREO RES! LGST REVERSi\l. l 80 Di'dS -HJ82.0fJ GCWJFl30 ATUL KL\-1AR SJNGl cg,;( sgst if< ,!c.l:u.,tmutt entri~., Balance wJth statutory mithorities
6,09,10,140.00
s
(X)
&
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231
.,.
~,,,.,
2; ;r $
0
2
~(
&
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232
!NDEf'Ei\!02\'\lT IHJDlTOR''.S REPClRT

TO T'HE M E{VH:H:Ks Of IRE() ?'1 RtV J;/'f'E
'J1o;;r:2 St21ndards 0rs .wtner

t·~inanclai Stat.::rtH,)r)::S sectton of our r<::.port,
t:thics issued bv U;ti.! J:istitute of Ci1cu"!~-;;r;1c f\.ccountants
a;·c to our
::nt."f:11_cv10 i,nd i\S stat:enlf'.ni<'lr

'Nh1-~th0r fh>::: Jth:-::r i:1fonnatlon
(1u:·lnq
&
\5 0
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233
&
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234
We also provide those charged with gov,,rnance with a staternent that we have c::imr,lied w;ch reievunt ,:thi~al
requir,~rnents regarding independerce, and rn communicate with tr,em '111 reiatlorships and other in<1tter,,
may reasonably be thought to bear on our independence, and whrjre applicau:e, relcted safeg,1<1rds.
Report on Other !.ega! and Regulatory Requirements
• As requir-ect by the Companies (Audicor's Report} Order, 2016 ("the Order"), is:,,Jcd
Government of India in terms of sub-section (11) of Section 143 of the Act, 1"le s.ive m the
a statement on the matters specified in paragraphs 3 anr.! ,; of tt1e Order, to t'tie ,:xtent applkable;.
2. As required by Section 1Jl'.3(3) of the Act 1 we report that:
(a) We have sought and obtained a!I :he information and cxplamJtions which to
and belief were necessary for the purposes of our audit.
(b) rn our opinionr proper books of acccJnt as required :,y :ai.M have be-:::n ke:pt bv tr0 Cornpar~y so :ir
it appe<1rs from our examination ot those books.
!he l::lokmc(" Sheet, the Statement of Prof:t and Loss (1nciud1ng Other Cu<'r1 pr<)hf:nsIvc income), t1,1:
Statement of Changes in Equity and the Statement of Gosh Flows dealt ,,1th Jy this Report are
agreement with the books of account.
(d) rn our oplnlon 1 tt1c oforesuid sti.:!nd'-i~one !nd t-.5 firv1t1ci;JI stnt~meot:s ::ornprv !<"dtt·1 the Tndi:1'"
Accounting Standards specified tmder Section 133 of the Act, read with Huie 7 of the Compc,nit:,,
(Accounts) Rules, 2014.
(e) on the basis of the written representations received from the directors JS on 3~ Mcrcn. 20 l9 .,tk:1
on re<:ord by the Board of Dlrecto,3, none of the directors 1s d1squal1fiec: as 0n .1.l Morch, 201.'I
being appointed as a director 1n te,·rns of Section 164 ( 2) the Act.
(f) With respect to the adequacy of tne Internal financial controls with rcfe:encf: to 'inanc1;;,I sti:lterne,Y,
of the Company and the operating offoctivcnoss of such controls, rcf,,r tG ou,· seDnrate Rcoort :n
"Annexure El".
(g) With respect to the other matters to be induded in the Auditor's Rcpo(:: in ,,ccordance wim ri'1,
requirements of Section l97(16j of the Act, as amend<:d, U,,;: µrnvi:;;iu11:,; ,,{ 2;v,cil,1 1;:;;, ,.,; · ,.,,, "
not ?.pplicabie to the Company since the CrJrnpany is not ;i public comc,inv 01:(lw· s,::,;:;,.:,'
2(71} of the Act.
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\1Vith r0sµect t1J ::he other rnatte:-s to be lncluderJ i;-1 the ;\ucHtor·s RepGr~ in ac:onJani:..:e wkh ~::,n•.1 1:, of
th() Cornpanics (Audit und Auditors) Ruf1.:'.!s 1 2014,- in 01,,;r opinion and the of :)u;- :nror'"1'~2;:ior-i
anct according l:G• tl10 expfanabons given to us:
TI1e Company has disclosed the impact of' penning litigations on h; •~rinndal ix•sit,tm n ,,,;
standalone financiai statements. Refer Note 41 (a to g) and note 44 the stancL3fone lnc .1\S
flnandal statements.
iL The Cnrnpany did not have any !ong·-tE'!rm cc,rtracts indudin9 derivnthle contracts for whk!- r;:;,~(;rc
were any material foreseeable iosses, Refer Note 41 (i) tc the sr:ando!one Ind AS fin,n::10!
staternc·nts.
Hi, There were no arnot.Jnts \Vhich were requirer:! tG be transf€rred to thz: investor Ecwcauon and
Protection fund by the Company. Refer Note 41 (h) to the star:daiorw lr':r.f /i.S foi,mciai statements,
for S.N. Dhawan & co LLP

Chartered Accountants
Fim1 Registration No,: 000050N/N5G0045
J:'
-~"%
VineshJain
Partner
:vlemb,~rship No.: 087701
iJDlN: 19087701AAM\HQ5473
?face; GurgEJon
Date: 14 November, 2019
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Annexure .A
{Referred to ln paragraph l 1.u1der 'Report on Other Legal ancl Regulatory Requirements' section
of the Independent Auditor'1;. Report of even date to the members of Ireo Private Limited on the
standalone Ind AS financial statements as of and for the year ended 31 Man::h, 2019}
(a) Th•:.: Comp,:my has maintained proper records showing fuil particukirs, including qoilr.titat,ve
details nnd sltuJtion of fixed assets.
(b) T:";0 Company h;is ;i program of physical v,0:nficaUon of ;\s fixed ass,-'.ts under which
f;xctl assets ~t!~ tn <1 phJsed mtJnner over a period two yea:·s, whKt"l, u1 c 1)1
0p1nion 1. Is rc~sonab!e havin9 reqdrd to !tic size of the Cornpany and the nalure of Its assets.
ln accordonce with this prograrn, aH tht.~ :ixed <1ssets 11vt'.:re venH-ed dur¥:n9 the year endcc
31 March, 2017 ar:d ~H::cording to the infDttnatioir ,a_nd expi21natio:1s 1,;f·vcn t◊ us_, no materi21'.
d:screnancies were ;10ticed on such verification.
(c} AccordU19 to the ;nforrnation and expl~;rv1tions givt1n to u-s and tt'1e r1::cort1s exarnincd by us,
;rnrnov,ible property (in the nature of 'fixed assets·) arc self.·constn,ctcd buildin9~,
cornpnsing of sample flets, site offices ancl sc11es offices. The Company holds title deeds/
d~ve!cprnent rights on land o~~ vvhh:h these tHJildinqs are constn.Jc:ted.
ii. In o,.1r o:)irnon and a.-:cording to the! information and expi.,mat.,ons given to us, hd'li:;g resard to the
natu(e of irwent.ory (,.mder head "Project in Progress"), :he ptlys1ca1 verifii.a,,on by way of
verification of tlt!e deeds, site visits by the Management nnd veri!'ical:lon of extent of work
COtripicUon by cornpctcnt pctsons, 0rc z1t r,c~osonabh: intervDf:; Dnd no n1uteri~I discrepancies were
noticP.c on physical verifica~ion, Accordmg to the inform,1Unn and r:xpi,ir1at101s qiven to t.:s, tt1e
Con-tpany does not: have any , nvcntory of stQH~'.::. 1 ,;pzH'Cs or nudcins rnateria!
W, i\c-::ording to th◊ information and exp!crnations 9iven to us, th•:! Ccrnpan·✓ h,:ts not •:J'i:lnted any loan,
secunid or unsecured to companies, firms, Lirnited L.iubi!ity ?c1rtnerships ( L.LPs) or other parties
covered in the rcgistt1r maint;:;dncd under Semon 189 of thr, AcL Actordingly, ti1e provislom; of
clauses 3(lii)(a), 3(iii)(b) 3nd 3(iii)(c) ,)f tho Order are 110t ilOplicnblc.
iv. I:1 our opinion and according to the informatior: and explamHinns given to us, U,e Company iicJ:\
complied with the prov,siom; or SE?Ction 136 of the Comparrn,s Act, 2013 in rcspt,ct of grant of
!oun:;, rnvk.ing invcstrncnts, :)nd providing guarantees 01H.l sccunt:~;s.
v. In nur opinion and dcconiin,J to the lrir0rnv-iucn a:10 t'Xpl,1n?1~k1ns giv<~n to u~, tr~e Company has
nat accepted any :lepos:ts during the year and rtad no unctairncd deposits at the bcqinnlng of the
~vH:hin the rneaning of Sections 73 :o 76 of UH~ ,!\,._--;t t"lnd tht! C::ornpanie::-.: (Acceptr;nce nf
v<::.;,,;rn.a) Rulesf 201",t (d'l i~nded), t.he or·ovi~;i(;ns of dause: 3::v; of the Order are
not app!icablc:.
vi. 'Ne have broadly revic'Ncd the books of account :ntHntamcrJ oy :11·~ Company p•Jr·st1,J nt to the Rule,;
rr1nde by the Central Government fct the r:1aintenance of coiit records under sub,.-section (1) ct
Sect:on 14.S Qf ·:he A•c:t in respec:t or Con--,p~Hr./s r0a! 1::statt~ proJ(~cts and t'.)re cd' the opintor; that,
fr:i.tk:\. the accounts and records have bei:::::1 TTl<Hie drHJ rnalntaincd, i!owever 1 ·.:-:c:
nr;i- rnride a 2xfl:ntnai_tun of rpcords vviU1 .J ·,/e'N t:o ,Jetc:Tt·dnr'., ,,,,i1·11;:thcr the\"
tn the lnhJr:flr,1tion df:d cx:)ldn-:-.1Uo11s to tr-1, otr'2r· U1-an inccn'h:: unc provident
L~H-1our CPS<.,. rY12 Ccnnp~:HlY ls n~nu1~1r in 1~:-H.iispute 11 statutnry dues incJudin<;
dt.1ty of custorns, tlOOC~ 2.ui<.J '~t:i',1U.. t;,'~ tdx ,..int'. -.,V1<~r n1 ✓i:.cri.)l ;:t-:\tutory du\~s, ?<1 <,;);Jlic<:1b!et to
the ;1pproprti1tc 0uthont:0s, rho(JQ'.'1 trerc nave Ot~<.~n ·sigr-;,fii:t:nt dcL)ys ir1 fe•N c:a~E~!1< Th('.
operations of the (jfd not t~ive cs:c to !iat.11Hty of ecnp!r;yecsf sl1;lt:~ 1n6ur:H1t:2 durin9 thr':
>:1rr1otH~ts jJe;yabt~ respect ther;1c~'j wt11ch 'NC?:rc outstanding at the
cnoce that'! sit rnont;·1s rrorn dd\.~ they becarne pnytiblc are as
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237
Name ofihe N.iture Amount Period to Du<: Date of Remarks,

statute of the (Rs. .in which the date payment if cl!1'f
dues lakh) amount
relates
lncome Tax Tax 703,2.0 2017-18 JO P,pdl 26 April, 201,9

Act, 1961 Deducted 2018 (Rs. 396-29)
-j;) income Tax

al Source
Tax 775,13 Aprii,:fo1S 7th 0r.1y Vc.nious dates

/.\ct, 1961 Dcduct?;:d tu r'\ugustf of ;};f~
at Sowrce 2018 following (Rs. 403.7? on
morct'i 26 April, 2019,
Rs. 204~5 !. on
30 /\pril, 2019
~
and Rs . 166.90
on 27
September,
2019)
The n.6~ ju!y, 2018 15th oay Vari OU.$

Employees' Fund and August, of the
Provident 2018 foll1Jw'.ng (Ro;. 36.79 on
Funds /\nd .''fH}r1C1
12 t,pril, >:.019
and Rs. 35.8'-i
::m ~~5 April,
2019)
incr.Hth?:"'tax a11d s.::~rvk::: tax that

ziccount of any dispute, 9re ns folro\v;,•
Name . of the /\mo,.;nt {in Rs. Period to which · forum where

Stat1:.1te Lakr.1s) thn amount dispute is
relates pending
2005~06 to Cen::rnl Excise

1944 2009-~1 D ! and Service Tax
i\;:,eli,,te Tribun,d
Income Tax Act, l:le<)me T:1x 28.:,. 28 Company
1961 fded rectdicaUon
fn r ::or:ection
lnconH! Tax Act/ L·~cofnt:: lax tl12 ccrnputatton
1961 of ::il:rn.:')nd
Tax
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238
· Pi,rt:iculars Amount of default ?eriod of default

as at 31 March, 2019
. CRs: In lalih}- . ·-· .
Deferred payment Habilitv 3,618,20. 25 Apr::, 2015 rn 31 March, 2019
including interest thereon
towards development cr1ar·g es
pc1yc1l)le to U,e GovE!rnrnem
Loans bank or flneH1dal

instlt:utiOns:
Stnndani Cl1,wten;d Bank
( Interest on
India !nfoline Housing
(Loan indLJdin,; interest)
PNB Finance limited 970.81 Ocrober, 2018 to Much.
(Interest on
. ir,.:Jt;;bu[i,; Housing 1.47.:n .t,pril, 2.018 to MMch, 20i.0
Urnttcd (Interest on lo~1n)
However,. t:1t.~ Corr1pan·:/ has not d0fDu!tcd in repayn1ent of dues to debcnture,¥t·lolders crt'~
yectr,
Ix, In our opinior: anct <lC<.:ording to the information ,ind cxpL,nations given to us, the Corrn~;;i"; did
not raise moneys by wv.y of :niti,:,I pubHc offor or further public offer (inc!ucing debt instni:T<,.nts;
r:1nd cHd not t1avt any terrn loans outstanding during tht~ yc<1r~ Accordingly, t'.·1t--: provisions c:f c!<'1t:s~:
3(\x) ol' the Order are not Hpplicable,
x, To the best of our knowle<19e and according to the information and exp1<:1nations given to us, nn
fraud by th,:, Cornpanv or en the Comoany by its officers or ernpfoyees ha, been noticed or n:pon:ed
during the period cov,,rcd by our audit .
.:i. The provi5lons Sect.inn 107 :if n1e Act read 1;vlth Scnedule V to tne Ac an:: not 0ppHc;ibh:: to ti'(,
Con-1pany s1:1c2 the 11.; rt(Jt 3 public cornp~niy ftS defined under Section 2(71) of ~!:c /\ct.
c:!z-;,_;:;e: 2(:-d; Q\~ the Order rr:t 1pp!Jcab!s-,
xii, TtH:~ Con1;>onv l~ nut o Nidt:i Cornp~?ny, Accordingly, provismns of Clause 3(:<;} of' tht.-. Ordr-•r
applicable.
xrn ln ot1r opinn.Jn and £;cr,:ordlnc to UH:: lnfor1nutir:Jr1 and ~xplanattons gtven to u:;., all tran!,d(
th12 t"Oiau:--;,d part:{{1S are in ;·:n:npl!,H1Ce ·wit11 sz~ction 188 of 'Act, ,11nere appftc0b!e
requisite ciet?iL-1 r121\1e t>eer; d1scl0set1 tn the standalone rnd AS firranci0I sb'!ternents etc~f as rcoua'cel
stardards. Since, the Cornpany is t) .~1rivatc limited
, 77 of the Act are not applicable to t11<2 Company,
Dc:-inq , :h2 Corr~pdnv :1ot rnade any pret0n·~ntta! al!otrr1erJ' or private p!ace:tfif'~
sh<:>(t'.:~, ry" fully nr portly C(HivA-rhbte riebt?ntures,. Ac(orziinqlv, orov!s;ons cf clau5e ](\1\1) of UH:
Ordcf' nor; ::1oµlicubk--,
>:v. in our GUH1;c,n ,:_;nd dt:,;,,:,:vn1:r q tG rh 1.'~ inforrnation ani:J q1vcg t•c: usr the Cornpan)1 ,1n<;
not intD dfP/ rH)!'1"C.tt:'>h trun:-;,;icUons vvith or per::;on,;. c:onrH:-ct·P,:! ',Nith th2·rn
covered :r.tnder Section 192 uf.tne Ac:L Accordlnq!y 1 :;covis!ons of d\:H1s:e 3(xv) of the! Ordt.:r 1)1 ,-,ot-
appli
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239
Thr;, Con1;:;1)ny tS n{)t n~quirer.t f);.? rt~gistered under Section 4S--IA ~1f th? R~setvr~ :3e,nk or Jndiu
Act 1 1.93:t, f\::cordingiy, provisions of dausc 3(xvi) of the On:Ji::r are not appilcabie,
For S,N, Dhawan & CO lLP

Ctl<Htered AC(()IJflt'?UlfS
Finn Registration Ne.: 000050N/N5000'15
,/}:
~vJ{
Vinesh Jain
?artnBr
Membership No.: 087?01
UDIN: .19087701.A.A,A.AHQS4 73
Place: Gurgaon
Date; 14 Ni::we:n:ier 2019
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240
INDEPENDENT AUDITOR'S REPORT

TO THE MEMBERS OF IREO VICTORY VALLEY PRIVATE LIMITED
Report on the Audit of the Financial Statements
Opinion
\-Ve :,ave a1;ditet1 thEi financial stilternents of Ireo Victory Valley Priv<lte Limited C'U:,~ Curnpc:ny"), wh,d·,
the B<1lance Sheet as at 31 March, 2019, the Statement of Pro!,t i;1nd u,,,;;
dlld th,~ Sti'lt•~mcn: of
Flows for tho yct,r then emk,d, and notes to ti'e flnanc1Rl srntemems, inclucnns 1i ~u111n:ci1y of signif,c,mt
acccuntng policies ,md other explanatory mforrrml:ion.
In our opinion and to the best of our information and accordinq to We explanations 9,vcn to us, u-,e afo,·esa:d
fin0nc1<1i statements giv 1J t:i'e information required· by the Con,pan,es A<.:t, 2013 ("the iu the manner so
n"q,iin,d and give a true ;,nd fo1r view in confonnity with the Accounting Standdrcb c1ndcr Section
DJ of the Act read with the Companies (Accor.mting Standards) Rules, 2006, <1;, ,w,e,,ded 11ml 0th,,r
,Kcountin,1 principles 9encrnlly <1ccepted in Ind',1, of th0 state of <1ff2irs O' the Company ,,,; at ; i M,11 Ji, 2019,
and Jnd its C~lsh tlows f'or the year· ended on that date.
Basis for Opinion
'Ne conducted our audit in awxdance with tr1e Standards on Auditing (SAs) spec1fi 2d 1,i,,jer s,ceuo11
of the Act. Our responsibilities under those Stc1ndards are further descr•ibed in the Au;;fit;cr';
for t!ie Audit or
the Financial Statements section of our report. We are indepe11CeTi <.Jf U1e Compi'.lny in
accordance w!th the Code of Ethics issued by the Institute ot' Chart("red Accot.mt,ints or lnd10 {"the ICAl")
to9eLhcr with the ethical req,Jirerrnmts that are relevant to our audit of the financial ;tatements un,Jer ti,t'
p, ovisions of the Act and tl1r) Ru/es thereunder, and we h,we fu!fi!led cur otl~er cth co! rcspon::;il.Hlitii;;s 1n
<lCcor~fm1ce w,th these reqtJirernents ,rnd the tCAl's Code of Ethics. W,~ beli,we Uut the audit: evidence WP:
have obtained is sufficient and appropriate to pr-ovidc o b,1$is for 01JI' opinion.
Mat<>rial Uncertainty Related to Going Concern
V\ie d:--aw attention to Note 29 v1hlct1 indicates tl".at, lhe CornP<Jny th;::; ac<:\.;,inutatt~d to:::.ses ::ind it(~ n,:?l wor~t~
bccci FuHy eroded, the Cornpany bds been incurrin9 losses t1nd, UH:~ Cornpony's (:J..1,-n:·nt tiah,!itic~; c:<.t:C(tdr:j
h1J~>
its <urrcnt assets as r.Jt the bai<H1ce sheet date- Thes•~ conditions mc!:cale the ex $Lt!P1..~ vf 21 ndt("f'•(;\
un1.:dt,1:nty that rnay cast: significant doubt about the Company's ,1biiity to contull:<: qonq cunv;;,•·
HovH)vet·, ti1e flmmdal •;tai'ernents of the Company nave been prepared on d 9n,:\9 , l)i n,·ri (Jc1:,i:, fur C:,,·;
ri2dsoq:.; ·;tateti tn the sale! note.
Our· opinion is not modifi<od in respect of r.hls matters.
Infonnation Other than the Financial Statements and Auditor's Report thenrnn
1'fH; Cnr0pt1ny''s 8()ard of D~rrJctors is re~pcnslb1c for- the a:h~-:;r inforff;ation, The ouv-::r ::-~t'onn(sH-;on curilpi isf~S
Lht: Director's Report( b:,J dtH~S :1ot include tt1e financ:1al state:rnenls an0 uur dLn1to:.,~ :-rr,nrt thcrtnn
Our upmion on the nnnncin: ::;taternents does not cover the tJU1•;:r infor."tit:1Uur1
of conclusio:~ t'.hcn.~on.
ln coni1•:'CiJon \Md;h 0{1r audir of' tr'K1 financal str\tt~rnents 1 our re:,p~:ina.ib;\;~y i':; tc r :\J,;; 0 ·1,:~t 1p(on11.:1t:1Y1
,;;:h~ntiffr;d obovr:- when it becorncs availob!e ,)ntL in doinq so I cor:;-;;idet v,;hct hv1 n:hei ()!; b
'tT::.:tc:rl::li!y inconsiste:~t ~viU1 the ftnonda! staterriE:n.ts cw our knowh:>.rJgp obtained n th} ::.udit, or ("1-ther1,.v'.SU
.,·1pp(~dt."·, to he: n·i;.:,ti::rklOy ffiisstated.
\i\/hen he read the Director report, if 1Ne conclude t!li:!t thcr(!

1
i-equTei.:; to cornrnunicat<~ the rnaU~cr lo those d1drged 1t1!th qoven~an<:e 0:vl

dppi1t,:'f~:)ie !avvs and regulations,
Management's Responsibility for the Financiaf Statements
n:c r ·,;::"~1:-1ny',:;, Board of o:~"\'.c~urs '.s n~sr;a~i:.;:b!e i'or :no rn.attc~s

r·t:sp2ct :o the of t:·,ese standaicne fnanc;al std>:fruer:cs
fii"!ikldul p::;~iliGn~ pl!:·rortnancG dD(l Cf\~;h f!ov,.i)~ of V1P (:Jf:'"Wi'H:v
Jt:r'h;nJ!ly iJtccp~...::d 1ndi0 1 i:'1clud!n9 t'."10 /\c.:-:nunt:ir,9 St.::i~:i ?L'"rJ~::
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241
/\r:t. Ttus also 1ncruch,;s rnaintcnance of accorcan<:e 1111th thf:. 1
safegu;;;rding of tile assets of tt1e and for p,eventin,; and detecting frauds
and other selection and application of appropriate account:in9 po!i,::ies; an;j
estir.nDtes Dre reasonable and prudent; and design, irnplernent,Jt:cn tH1(i rrklintennnce of uuc"'-'"'L"' lnten:al
fru:Jn(:lal C(1nl:rols 1 that w(J:re opcr21tin9 cft\.➔ ct;vefy- for ensurln9 the dccucacy t,nd cornp!E~Lenf~ss of th 1·~
ao:ounUn•J rei::onJs, relevant to the prep.:1r8U<)n ;;tnd presentdUun of Cht:) $t:an<.ialon1.-:,~ r,ndn<:id statent~nts
giv•~ .a tru,:: and fatr· view and ace free frocn r-nalcr-lai rntsst0ternent, whether d\JC ::o fr,:ud i'_~rrcr.
In prcp;)rlng tr:+;~ fln~n1dal slatcrnents, rnanaqt:rnt:-nt is "'esoon\:;lbie for Jt<'::.t,;S:,Sinq J11,,~ Conipnny'!"
conttourz: as <) q(iing concen1 1 dlsdos!ng, as t)ppiicabk.':, rrPJtters r-,1;;:tatcd to goiqq i;onct~rn dnd usin;J the
concern btisis of 1.1cco:.mr,ing unless rnanagement either intends to liquidatQ t.he Compon•, or to ceas,,
operations¥ or has no realist1c att-<:rnauve but to do so.
The Soard of Directors are also responsible for overseeing the Company's finantiill reporting :)rocc,ss.
Auditor's Responsibilities for the Audit of the Finan<:ial Statements
Out art~ t:,;: obtain r~2asonabie assuranco about wh 1::t1·1t:~r the financial ~.a,ati;;:n-(tnts a~~ a ~vhoie <':H'E' f'r(:~i::
rniss;t~1tt,nncnt 1 whether due to fraud or error., an,d t<> Ss:-;ur~ an auditor 1 :; rcpot~ that h1c!udc0 ~
op1nio11. Rc;-1:~;on,Jbfc .:J::>sUtiH1ce Is u high lev.:~/ o( C)S.Dur;'.:)f'H.::e, but not;') fJuar-,:·i1'lt(:<i 'Jt,)t' ~,,1 dt1(!i! O'):)Cluctccl 1·1
accordar1ce with SAs wi!! always detect a rr1a:c:1al rnisstatern1:~nt v-1her: :t cx:sts, t,.,11:~::;t,1r:crncnts f:an an:,;c~ fr,_.,,·,:
fr-aud oc erTJr and ore i:cH~S1dered rnaterial if, tndividually or- 1n thB 099req.Jte 1 th:?.Y couki reasonably
1;~x.:Jccted to m7luence the econornic decisions of users taken on the bzt.;is of these find;1ciJ1 :;tr1ternt:nt:;.
A.s p;-1rt ot an aLEJit in accordancf? v1ith S/1.s, we. exercise proi-es-:-:1or~a1 Jud~irn(H"rr ;~nt: n:::-in•t,1lf', prnr1:~ss1or1r-·,:
sk(~ptiusrn tl".coughout U:t: ~H;d\t. \Ne al~:.o:
Identify <lnd 0ssess the rLsks or rnateriat rn!ssU)terncnt of the l'lnanciai st-ate:r1r~:'lt':'·~, 'l{f1et'Ler due to rr;::L1d
or {:~rTor, desiqn and perform audit proce(iure,:::; responsive tn thu::;e '"isksr and t,;.)t,;:;:1 audi:· evidence t·h;1t is
sufficient and a;:Jpropr!atC" to provide a basis for ot-v ()plni(.1rL The risk c ·: net ~=c~ecUn9 d "ndlt::r:a!
rrnsr~tater:H?nt rcsultin9 fron1 fraud f~; hi9her than for CHh? n~5;u!Ung frcrn eTOt; ;i:i fraud ffL!Y ,nvo;,,(:~
coliusion, forgcrv, intcnt1on2:i omlss:onsr misrcprcscntaUons, or the OV(:?:rnde of intcrnJi control,
Ot>:,:11:1 ar: urHJerst,::inding of intcrnai control teievant to the 1:1udlt in order· ~o dc,5J9n pto((:Yi1 ;n:,,-:: t:~,y·
an~ in the c1n::::qn1st1Jnccs but not for the purp,,::se of i::::xp:"C'.:'.iSli)'.,J an th-2 <~ffec:.. ver·c;·;5
:nternai controls.
Evdluat!'..J t~,e approprlareness of accounting policies used an<: ltlt> reds0ni:!bl~n,~:ss ::-.1c:oqnUn9 f:1SUr'rP1h'.'-,
,"<nd rel;.1te:-J disdosunJs made by rnanagcnv.::nt.
Cr;;--1:~!i:.tdr~ on the <Jpr:wopcic':ll'.erH?SS of rni~n2H3e1r1Pnt,s usr:. of t:hf; c;oin<1 cnncc~rn h?Fii:;:; o~ r::.:i';curitin~J dnd,. b/:i~;:~d
the ,.JtJtiit evidence v1hctrH::r ntatenai vnc1?tTa1q:·y t~xis:s refnt<:d tYicnts condirion•,; t''F:t
Conw,any":; ability to (:onli~HF: dS d qoin9 <J)i :.:u 1:. u coi:(!u<.h:
urv:f.:-.~ta1nty -2-X.'.:.:;t'f:.:, W•~~ are t'f'Jquir(;d to draw r.::L In uur dddr~ur ':< ;.;!p1:,r t to t fl;_i ~'t:!~r.r,: !
rji:;c;nsun::s iq thfl hnanci;1! $t2ternents er( if :such disdt:st.;ur(~:; rnat:equ.n:cr ~.o .":1.::-dil·y op n;t);'l o~r
;;1n:: bw:;ct:f on the: oc;dlt evidence cibtz::incd up t!L~ d.J:J~ out !·'.;,,:'.v: ..:'l'-:: 1
f;•1c-·1ts or conditions rn~Jy cntJSC Lhe Ccrnpany to ct:;osc t:; conUnuc as a L
.stru,:turc and c0,,,1ti:::;l u· firknkid1

,il:)u;·t"<:ir dnd /in11nn21l u·idcdy;n~j :1
rndnrtr:~r t.haL achieves fdir presentation.
\/Jc c:in1tnunic:,:1tc~ v,.·ith th(•sc ch(H"gc:ct with Jov<:~r,ancc r,:;q::r,.Ln9,

ft'i('. or the i:.'!UtJ\t (iU(H: fwdings, iO(hJdin9 \!fly
;;s,r
provitV.'. L-wse ,:h;irqed v11iU1 9rJvc-;--r.2;Pcc l/,;1th (:1 state!':-1-~~n~· t··,1t Wt? ti-JV(~ (ornp!
n?9i.Hdlnq itL'!t:f,H?ndenc\~/ and to ~:::t7HflUtllCdl.(; ,,..,,.it:,
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242
Report on Otner Legal and Regulatory Requirements
1. t,s required by the Companies (Auditor's Report) Ordor, 201$ ("U", Order"), issued by the Central
Gow,rnrr:enl of lndia in ter rns of sub ·sectt0n (11) of Section 143 of th: Act, we give in the Anrexur-e A ,,
jttitemnnt en the rnatters spocifi,1d par::i9mphs ~ and a nf rl'lr Orclf:1', :O :lie e:(tent applicutJie.
;1 . As required by Section 143(3) of the Act, we report that:
(:1) V✓ c hav(~ sought and obtdined r:1U the, inforrnanon nnJ cxpl<.~nntic,r:s 1r1hich to the bes~ of our kno·Ni-;;dge
,1nd belief ..,votr; nf~c:essnry for the purposes of m.sr audit.
{b) In our cpin,011, µroper tlooks of i:1Cco,1r1t 0s by IDw hov•~ boon kept by the Comp0rv so fa:- as
it appears from our examination of those
Th0 Bafilnce Sneet, the Stiltcrnc,t of Profit ard Loss and the Stdeme:~t of Ca:;h Fiuw$ de,J!t with by
n·.is Rcpc}rt ::tr~'. in f:'t9re 1?(l'lent Vtith the b0.:;k~: nf r:t.r:ount,
(d) In our opinion, the wfores(itd ra;an<:!<:1! ~,tatcncnts cornpiy vvitt': Sten<J(ird-s specit'tcc1
under Section 133 or the Act, recJd witJi R.uie; of th0 Corroardes (Accovnt:,) 2.0111,
(cl On the basis of the 1,w,tt:en representations received from tl,e directors a, on :n M;,rch, ZO l 9 taken
on record by the Board of Diroct:ors, none of the directors is disq1.:a'.'fied 2s on 31 March, 2019 frorn
bein9 appointed as a director ir: terms of Sfxnon 164 (2) of tt1,: A~L
(t) VVirt: respect to the ;:idequacy of the internal t;nanc:al cont,0ls wI:t1 rde1 e11ce t,) f,i1,H,C:dl stoL<..!menb
of tt1e Cornpany ;-inC the nperatinq eff;:~ctivencss of such c<vit:-ob, refr~r to our st:!pan)h:: Reoort in
~~Annexure 8",
(g) With respect to the otl1er· ,natters to be included in Uk, ,A.u('..;t:,;Jr"s Repc,r-t in accord,,nce w,th rhe
requirement!'; or section 19'7{16) of the 0:; nn1endr~d; the prnv:s;,,or,s of' Section 197 of r.'tie Act are
not applicao!e to tht0 Corripany sincz: tne is nor n puhhr con\Jdny as df~f\nf:.J u:1der Section
2(71) 0f the Act.
(b) VVith respect to the other rnattcrs to tJ(:} inclurk:d ii 1 Uv;: Auditor's t<.;;::po:t in 1,1z;cordanc,:: vntr1 Rulf~ 11 -of
the Cornpnrlles (Audi't and Ruk.:s,, )CH 4, ,ri opHuoi! LG th(;~ best of uur 1ttfonndt1on
and 3('.CO!'(Hn9 le th0 f•Xpfa11~)t!O()S t0
HHt Curnp0ny doi?S f1t;t hav~~ (,1:-iy

Ref<:r Note 2:} (ct) to the: fir-,ancir,JI st<itcrn,:::r-J.:;,
ni. Tlv.;re \Nf)JY:.~ no aP'hJt.:nts which vveit:: n::,:;ui:t.:d be

PrnliY,l:;On FuPrl by the Con1:J,,ny, Rcf,:r h!{)li' 7:i ({)) co U1c:
tor S.N. Dl1<1w<1r1 & CO LLP

Charte,~rod Accounr1:tcts.
cir-m Registration No,: OOOCSON/N'100(H5
r;f'
~O;o
Vinesh Jain
Partner
,~'1.: 08/XOJ
,AAAACL93i,/
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243
Annexure A
(Referred to in paragraph 1 under 'Report on Other legal and Regulatory Requirements·· section
of the Independent Auditor's Report of even date to the members of Ireo Victory Valley Private
Limited on the financial statements as of and for the year ended 31 Marc:h, :W:t.9)
!?) The Company ha,; rnaintaineri record,:; s,hoiv·no ;;ui! r,articczi,;1rsf inciudinq
qu:x":'t;tative d;;~t:airs dnd situation of assets.
;b) The Company hiJs a re9ular pn:,qrnn, of physical verir1c0cor of :ts t xe:l assets _indcr
which fixed bsseLs 2,1re verified at requk1r intervdls, "'vt1!ch 1 tn our opi~1ion: -·easorH.1t;1e
havfng regard to the slze of the Cornpany and ttie -:nrure of its assets, ln oc:con:Jznice
with this progn:Hn, a!! the fixr;d assets \<vere veriflr:d dunn9 l'hr:, y'e21r Pr:='.ied 31 f'/·i:1rch,
Z017 and ,a(.>;crding VJ tlle inf<;rn1ilt1◊n Jnct ~xp::.Jnauons <;rv~:n lo U-.-;: ::0 rntitttk-d 1
discreoancies w,,re noticed on suc!1 verificntion.
(c) Acco·""cting to thr1 !nfo1~rn<:1Uon rind t?xplanations 9iven to us and tr:e recorc5 cxarnin,::,;d
ust t~1e Cornpa;1y dor1s not hold any !rnrnovab!e pr:..".Jp1;7r!:v ( thi} ndttir-2 of 'fix ::d 1
Acc..,itdin;1!yf Uie piovi~~l(H1s of clnu~c 3(i)(c) oi" the t..)rd:\~r ilnJ ncl dpp[icnt:!c,
tL In our Qpinion and accor·d1n9 to the 1nforrcaUon Jnd e;,q;i;anat,ons 9,ven to u:.-;t h0•1ln•~ t.o Uitt
:-wture or inventory (unde 0 head "Project in Progress"), tlw pi>'/Sica! ven':cab:rn way
verificaUon of tiUc deeds, site visrts by the Manugement cHl(l ver-lfication of extent of work
CQntpJetion by ccrnpt.~tent pt.~rsons, f1ff': at tl'.'?dS(HlrJhle fnt·erv<:!ls ,:in:_! t10 rr1ate1~1a1 d scn:panck:s vvf.;:'t·
notice,:J on physical verification, Acco•ding to t:he :ntorrnat1on and e:<p!anations g;,,en :o us, th,.,
Company does not have any inventory of srnres, spare parts, or b:,itdin9 rnate·i?J!.
iii. According to th'¼ information and explanation,; (liv~·n to us, the Corn;rnny has nu
secured or unsecured to comp:rnies, Lirn:t.e,1 Uabilrty Partn,;rships
,:.:ovEtred In the reglster rn?1i:1tai11eci l;nder !80 of the Act. Acccrdinqly,
clarJS(j$ ~-J(iii)(i<:, 3(id)(b) dnd 3(lii)(c) of HH~ Otdt)r are 11ur dppi:G·d)h·~-
IV. rn Oi)r opinion t)nd to the inf-orn1dr:1on vnd cxplonDt··cns given to us tht,'..'. CG·np;)nv f-,:1·.:;
not ~ntered lntQ any covered $c1_.i,H;r1~1 1.SS d lSG Act. A~~r.,u::J:n~Jiy, tt11..:
provl:>icns uf ckHt>.<:: 3(1v) ()f thf:'.' Orr1cr nn::~ nor tJ;Jp:t<:r.it>!c
v~ In our to the inforrnation on(i expianat1 :,ns qiven

not tbf:: year and hdd nn uncl+1irned depusits .-1 ~, tXH~ Of J!nning
yer1r thr rne~nino o!· St:cuons /3 I'.\) Jf UH! J.\Ct. ~:·1d C>:i,npi:in,f:1•'.l of
Dcposilsl Rule~, 201'1 (,;1s arnended). Acco,·d:nr:J!Yi tt.,c provisk;:1s .;>f ci,0us;.: 3(v)
not ,;1ppHcable.
vi, vve have brnad y r~rv1(:wf:~d books of :1hunt-dint:~d tJ·>1 to ;~he Rules
n)Etde by tr~e C:~ntxa! Govcrnr:·ient· for tht:: rni:\mton~HH:c .:)f cos::
Section 148 of th◊ Act 1 ir: respect of Cornprw1v ::. 1
c:.;tJti:~ pro;<:ct nnd .Jre ()~-
pnrn<.1 facie, th•,:: prc:;crif,1(;1.J 1)((;(~\JnLi n1a1:1L-:1~1ed. Hnwev(~ , vv.:.:
hd·Ve no: ni~:ld+"~ a 1::x,:~:r:;11,a:i\'icn •-/vt:.:{1 ~:th1:::r t:·1
Ai'C' (;1C·(Ut'?tr:: 01' c,:::,z-np!f~t,;:,
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244
vll.
(r;l) Acconjiit9 to thE· 1nfcrrn2tion a0d cxplanatioris i;pvc1 to us, other tt·1dn de:ays in incoinc tux, :h<~
Cornpany is t·~gulcr in depositing unO\sp~tcd statutory di_;es indutHn~, duty yf custorns, cc:is,
good$ 11nci services lax a:·1d ,)tht~r rnat-~rtaI statut~rv Guest as appli::3t)IE\- :c th(:; ~~pnrop~·i,jte
authonucs. "ft1c opcrauon~; (1f U1e Cornpany did rv)I: s:;ive r~sc to linbiH:y of prnvtd0nt fund ,3;i,J
en1oloyecs' state insurance during the year, Furtb•::;r, undisputed an-:ou1ts paytlbk: in respect
~f1crco:-:f v/1i<;b were outstanding at the yenr~2nd ror d perioU of nivrt? th<Hi six rnonth:wi h"on1 ths·
date lhey becanrt: poy21b!e dre dS f'o!lows:
1 Name of Nature of i Amount (Rs.) [ Period to 'T Due date Datcof .

! the • the dues ! I which the payment
i statute 1 amount
relates
i
______ L. . ········----''------·
2,837,333 I 2017-13 ]0 April, 2018 . JU h:iril, 201')
Deduct.ed at
Source I
i
i
i
/ income Tax 7th day of the 30 .Apn!, 2019

I "
i lax /\ct, ; Dede cttd r::t ! followrng rnw1:·', {R;;.
l ~· ).
' J Cl('' :...,c~Jr(P (Jun0, 2li.lb :t)
s,::pt:emb.,ir, 20.18)
C,.C.:31,4!01
(b) Aci.:orr:trn!J to ::he infonT1dUor; ctnd expfanations ]iVt.:'n to us1 there rsr·r.~ ro due~> in respecL of
income-tax, duty of cu,;tom:,, v,0iue i:ldde(1 tax and goods ,md services tax th<lt htwe not ur:,:,1
dc:posit2d with ~he appropriate 0nthoriUcs on account of 0r,y dispute.
VH1. ln out op;niGu :::ind accon~l1nq to tl:e 1nforrn<Jtir:n1 anu t>:xplanations Given to us, ~-he Cornpa~ty has
not' dei\::uH:ed in lt;payrnent 0f khv1s or bcn··o\vings to ;y:-:.y firnncfal institut'on or g,:)venHr.~:;nt ur
uny {!up<; l.'} c'.el)t'-~!\t1,we,,hold(~r~> df...fflnq the YZ>Jr. The Ccirnp<;ny t'H.15 p() toa:1s or !Joi: c·w1nq:~ pi.:iY -1i;\,,,-;
to ~1 b,.rn k:.
In :Jr)r \..ip;;,;:)r: fJ:-.r_.i ...:c<,;::,}, di;HJ t:J t!":t:• 1nfor-rr10tfon <~nd ex;d.::na::ions giver tv u~;, the CornpJr·iy d;;i
:·1,;it r-:.'!S•i.' 1n.J1-:cy:.; :_;y w.Jy of intl:::1! '.:\u~;iic ,;)ff(~r or forth:.~;' p·.1bil:-~ offer (inciucHnq dcht tnstrurnent.s;
:~rH1 cit.J 1cl 11,'.\V(: dny ':crrn !v<;qs ~1 ut\}tz:·d dinq dunn9 hH.: vcaL /\ccordingh,, thP pr~nvi5~ion;::: n( ctntr.:;f'-
)(ix) u{ i.h>.:~ ()rot'~' ,.~rf:• riot d;)p!icr.:L!t:.
x. ·re the best 01· ot:r i<nov:icd9 1) .;u;d .J:ccocdtr>g to the 1nf'crrn0t:ion ~nd cKplan;:,itioPs 01v~>n tc: u:..:., 1i,:i
~r1Jt1d by Uic (l"Jn·,;;;;ny or on ::~H·: C:1rnpdny by ;L:s otT.(cr·s. nc ernp!oyec,s ho:: bean f':'.Jt;~,:(1f.! t~r t~~-.:pc,··t·,
dunnq rti?-:: p<::-:riud <U'lt.:r cd by our at,di;:...
:<i The prov>•:.1on-.c; ,--.'· '.,:,2ctlt.H) t 9 / ~1;. ::h{· f~C'.. redd witJ1 ':'>1:h~::du\e V to t:hc A<;r Jr,;1 not 21p;)irC!thk" t'{; U1c·
Cornp011y :,:;(:',;{: Co1ni}<1q·r i~,; r"'Oi n r;ut)i;c c:;rnpa:1y ::is d(lflned ur:dc,r Sc~·: on )( / 1; '.·1t :!ic,, .'\,·"
Acce+r',7H~ 1·}1y, pr;.•; :.inn~·; ,)f ck,use 3('.<: > of l'hP Ordr::1 r t:;rf: not or;plicab(c!.
>~11. Th(·· Cnrn;·;.:1;-:,,, 1~·

?:pf)i1c;:b1.:~.
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x:v, Curing the ( the Cornp~~ny has not rnade any pn;fen;ntlal aHo:;n1er:t or orlv3tc
shares ◊( or partly corwert!:ne clebentures. Accordingly, provi~;J<Jn:, of dduse
Order .;-1n~~ not' hpp!icabli:.0:.
xv. ln our opinion and ,:icccn;Jing to the n,formaUon and cxp!umit1ons given :o us, the Cornp;;;ny i'o:,
HoL t.:!nb::··cd into dny tH)n --(>'.1'.>h tn.1n~i:.H:tions with the directors or pCr$Onc e;:onnoctcd \.vith th0rr1
cov(~rec111r1r1nr Sru.:t;on 9Z of tt1f! .t\rt. AcconJ1ngiy( µn1vts1ons cf cl<Juse 3(xv) of tht• on.L}r :1-_)t
,ipplic,:,ble.
xvi. The Cornp<1ny net rc!quirca to be under Section 45"1A of t.:1c Res,=rve s~:1:1:< :)( trid:d
Act, 1934. Acl.:or·din(!iY, provi5il)rt5 of J(xvi) -::Jf :lle Ordf!r .:irn not app!:cable.
Fer S.N, Dhawan & CO LLP

Cv1rtered AccounVmt,;
Firm Registration No,; 000050N/N5000,15
u-.
~v"%
Vinesh Jain
Partner
Mcirnborshfp No.: 087701
UDIN: 19087701AAAACZ0317
Place: Gurgaon
Oac:e: / 1 Septembe, :!Ti 9
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TDS on Others than Salary
Month As per Challan As per books Difference Remarks

Amount deposited Deducted Deposited Challan Vs Deducted
Opening (7,03,19,879}
Apr-18 (45,74,883)
May-18 (1,55,31,348)
Jun-18 {1,54,56,316}
Jul-18 (82,55,774)
Aug-18 (1,22,11,747)
Sep-18 (1,19,28,772)
Oct-18 (1,59,06,747)
Nov-18 {96,79,326)
Dec-18 (1,16,01,453}
Jan 19 (21,87,228}
Feb-19 (83,89,360)
Mar-19 (4,42,20,699)
(15,99,43,653)
Net Liability (23,02,63,532)
TDS on Salary
Month As per Challan As per books Difference Remarks

Amount {Rs.) TDS Deducted Deposited Challan Vs Deducted
Op<::ning (1,02,86,358)
Apr-18
M;:iy18 (40,66,177)
Jtm-18 (38,51,133)
Jul-18 1,02,96,358 (70,47,764) 1,02,86,358 10,000 234E
Aug-18 (65,18,101)
Sep-18 (45,49,091)
Oct-18 (38,21,897)
Nov-18 {68,89,490)
Dec-18 (46,41, 756)
Jan-19 (38,48,114)
Feb-19 (64,09,791)
Mar-19 {93,01,492)
(7,12,31,164) 1,02,86,358
Payment during the 1 1,02,86,358

Net Liability {6,09,44,806)
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247
(16,43,10,985)
Amount Pending
for more than 6
Months
(12,68,97,353)
Amount Pending
for less than 6
Months
For CARO (16,43,10,985)

Sep due on 7 Oct (1,64,77,863)
1\bove six months (14,78,33,122)
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248
S.N. Dhawan & Co. LLP

lreo Victory Valley Private Limited
Statutory Audit
Period Ended: March 31st, 2019
Particulars 31-03-2019 31-03-20181As per Workin Variance Difference

Tds On Payment 3,84,09,567 98,23,440 I 3,84,09,567 2,85,86,127
Task Execution Memorandum[ Work Done

1 TDS Challans and returns were obtained from the management
2 TDS payable was reconciled with the ledger balance and were mapped against the challans obtained
Management Assertions relate..0_10 acc:QuntJ>~lance
Assertion I Description Remarks

Existence Jthat an account balance actually exists at the end of the reporting period V,:dfied
Accuracy and Valua that an ac..count balance has been. recorded accur2t···e···l·y at appropriate amount and valued
Completeness that there are no unrecorded balances as at end of the reporting period
Riqhts and Obligati that an asset o_::jiability belongs to the company issuing the statement
M~lm.=mement Assertions related to Qresentation an_dc:i_isclosyre
Assertion Description Remarks

Occurrence and
rights and disclosed events, transactions 1 and other matters have occurred and pertain to the entity
ob!iqations
Completeness a!! disclosures that should havp hPPn 1nduded in the financial statements have been included
financial information ls appropriately presented and described, and disclosures are clearly '
Classification and
Vt-~rifie{i
understandability expressed
Accuracy and
financial and other information are disclosed fairly and at appropriate amounts \J .r~ rifl e<i
valuation
~onclusion
Balance shown in books is fairly stated
_..=:;
V)
u\
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249
S·F'· l?l'\.iyv~n ~ <;<>, 1,l,P •

!~9.yi,;;12,xY!!l.fexfriy.,te L,imJt<',<l
§t~t>119'Y Al!dit ... . .. .. ... . . ..
f>.erjgiJ ~<>.<1!!<1,. t>l_aEch '.'11:sJ, ~Ql!I !
sum~rv of the TO_S.payablean~-Ti.:isPaid ....
\f~rified frcrn t:J:1,i books of accounts and the return.fille
'---:---c------,....--,-,-------=-~,--...,.,---,-,-,-----------".;u'-"'LCSillh,aa,,11,a;,!!n_ _-~Qr~
Opening Payable Paid/ adjusted Net Tax ,Interest ·
R9!11'1.~b~Js S\!lll of Debit.Ame Sum 9fCre,<litArn<>1,111tin.lt/\oriL .... ::9ttD,44Q . -3~7JJ97'L.. .... ·-·-··-.. -· . . :\.,QJ,9.S...1.l.5
Q1 65,95,415 ·59,57,!H.1 .iN~x ... :l,Ql,2.S,'.'!J.~ ·29,41,441 . §$,95.415 ·65,5L441 ·····
Aorll ·3.7L975 ..... June .:§5,il,.4.H .. :4~-.41,:!IS.. ·9'.S'i,81$E
Nav 65.95.415 ·29-41.441 Jµly :9.i,Jl5,iWL -nt±,Z!5.5. ..... Z9,.9Ll'~8. .~$:l..~8.. $(};3
June ·26.44.42$ .A'4.9 •i:.i/A&ll-e8.0.i :W,!12,498 3,21.326 . ·1,19-99,97?.
02 37.64.613 -83.10.002 5!'0 . l ,19.i;,9 . 97$ . :;::?.il$.\i<";3 .. ....4...5.l.459 ·t,:P.S7.J29
Julv 29-9LS2B -32,74.765 ;Q<::,t -l .YJ/f?rJ 79 -.4.~t,)J~f.z.:~.$c :.. ,,c••·-9:$.,21~ •i.§n.9.7,696
Ai;mn.t 3.21.326 ·J.8.52.498 · l,5.0.;17,§96 .. ~6A7,H9 3 91.1,9'.I vl,~};);3,~l,48
Seoterrb~, 4.51.4SS ·2L82.739 ::J.~JH> ,?3,12JJ ·2?.J•l.,319 :).99.643 · Z,09.7'7,80~ l:P. . . 24,175 . ,2(}_-Q.
Q3 8,1;!9,552 -78,32,581 -i,v1J.ni,01 ·33,Vi.894 .2 86 ..Vil. :2.,J9,47,047
Seot€mber ·25.924 ·7,.39,47,047 -;o.1q;.35. ·?.f.\9&l.li&J .
October 98,212 <?4,38., 7?.9 March ·2,69,61,683 -1.14,47,884 · ·3Jl4.D9,567 6.,25, 184 16,000 I2s-Q
Novembw '3,91.69 -28Al,129 -----~98.23.440 .-.. ·4,.01.22.3:iS~ J.1~-36.231 •3,84,Q9,:i§2 1, 14.31.636 ...... llh2.llJ .
Oecerriber .3.99,64 ,25,20.799 A ;i~
Q4 2.86.65 .. 1,so,21.934 . A-H 1.◊•·)595- , NM?it
lanulln' 2:,86.6S -33,55,89··<
febr'<-'arv 30, 14,63!>
Maren • l.\4.>17.iHH
P€:cernber ·2.03,SLO .Qc~r:i.nq P~V?blt: 9$,}3A19. .A
Grand Total 1,15,36,231 ·4,01.22,358 . P<\Vi,!Jlg WLS.eo 1 42.s3.?R B.-
Total payable for more than 6 months 2,41111,201. C"A-B
l:i).J!L.........._____ l-QS 06 452 . P.

fllet b'l)1!1J!="' 1.34.10,7!;5 . bC-0
P?Y~t!?/*P(;rt~,;l ~5 for ?&Y.:D f <<R~f¢r -?~djt r~port_> >
J?.~Y?.9!.~ .t9.. Q.~ J~.PQrt?<i 3$ 1 04,7.3422 (;;£.f <, < Moy,e1:rt¢J1~;.-- ?-
_ f:4YF~}tfU~t;r.)Jrt~L~1s)o: ·-· l.Q4,8112.9:L~ H < ~.fi~Jgr a.u_(:lit r.~_pqrt>_>
Net difference 7,645 l~H:G IIIMHJ
(})
+1
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250
Office of the
Assistant Commissioner of Income Tax,
Circle 74 (1}, Room No. 413, 4'" Floor, Aayak.1..r Bhawan,
Laxmi Nagar District Centre, Delhi- 110092
----"-P=h~Il-~.:..2-!. l - 22446705, E_:1\f.aiJ:.~<1~~-A_<:iJ;J,.~~~!,!-J;;gm~~R~~-~1-~--_____
._t~J-lo, l\Crr/Cir_ ·:?.:
.s•-·· . :'-PJ/13ank Attch, F?.eltiase/2_C_l_t'_)•_l_c_:;,_,1__·______ _ _I),~ned:
---- -- _____ 07.05.2019
_ _ _ _ ,,,, ____ ~,~~-~
The iJn:tnch lVlanager

Kotak Mahindra Banh
7 th floor Ainba.deep 13Ldlding, 14 K.ZJ:. r\,:targ
New Delhi 1100()1
Sir/Mn.darn.
Sub: Rel.case of Bank Attached in the case of M/s IREO Victory Valley Pvt. Ltd.
reg.
l'ie<1'.1C refer to this offin: lei.Her F.No. !\CIT (TDS) / AttactmH:nt «/ s 226(:\j/ 2018-
19 / 2537 dared 28 . 03.2019.
\lick: crur above r-r1(:nri<;;1ed not.let!,. b-e.lov.· rnentioned a/c no. has been fro;~en for
debit and confirm<"d.
Ym.,:·s fo.ithi,.dly,,
) ' ,:;::::; - • .,.,,,✓-'~
i ✓~-- £/
IDr. Castr~ayaprakash T 1
Asstt. (:orn:r.1,is~\onc·r c;f lrr.:ornt:~ TcLt;
C~irclt: 741, 1) ~'c:9,,- Dt:1;,,
1
Copy w The Principal Officer. IvI/s JREO Victory Valley Pvt. Ltd. rREO Campus ,
Arcbvi0w Driv(:, l.i.:/.EO City, gcll{ course Extn. Ro::,d, Sector- 59, Gurugram fforyana
122101.
Asstt. Co::nrnissioner cJf' incom,:-Tax.

Cii"ck 74( l), New Delhi
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251
·~t?ft PEL~I L 925503

j
i
ADDENDUM
.. , , ... TO
, MEMORANDUM
''",r, ,. OF UNDERST
. ANOiNG•
...
. '
THJS ADDENDUM TO AGREEMENT I MEMORANDUM OF tJNOERSTANO!NG
(h~reafter 'Agreement/MOU') Js maqe and executed at GurQaon ,m th!~ .~ 6th day
of June, ::?O~ i in continuation tb ortg1nal Me.morandum of Un.derstanding dated
August 27, 20·10, executed bet.ween a111he parties 11erein, and shall constitute
part and parcel of the original Memorandum of. Understanding. This MOl:1 ls
execu~ed by and
BETWEEN
Precfslon Realton. Privats Limited, a: company incorporated under the

Companies Act, ~nd having lts registered office at 305, 3.rd Floor, Kanchan
House, N,1rampura Commercial C9mplex1 New Delhl~15, India (herein<;1fter
~
:riili:r.red to as the i•pr~t,:ision/AVTHORIZED ASSET COMPANY,; (which
_ii if.~~~ion shail unless repugnant to the contetxt or meaning thereof b~ deemed
to Include its suQCessors, administrator, ~ttomey, nominees and permitted
assigns) of the First f'art; repre.sented herein b:.! its authorized signatoty
Mr, Naresh Kumar. L:

/,1~.,.·.". Y
,~1 L.____ c·· -
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252
27 AUG20l8J
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253
AND
aiu~ Planet lnfradevalopers ?rlvat~ Limited, a company incorporated under

the Compijnles :Acl and having its registered office at 40/16, East Pate! Nagar,
New Delhf·1100P8, India, {her<',lloafter referred to as the "Slue Phmatlland
Holding entity", which shall m~an and Include its succe5SQrs, admlnlstrator,
attorney, nominees and parmittet.i iaHlgns) of the SecQnd Part, represented
herein by its Authorized $fgnatory Mr. Sunil Malik.
ANO
Mfs. Global Estate, a partn~rship firm and having its office at E.47/2, Okhla
!Mustrial Area, Phase-II, De!h!•110020, lhdia, (hereinafter referred to as the
!Global i:state It.and Holding Entity", which shall mean and include its
successors,· administrator, attorney, nominees and permitted .assigns) of the
Third Part, represented herein by its Authorized Sign;;ltory Mr. Lalit Goyai.
AND
i'Vladaira Conbuild Private ·Llmlwd 1 a company incorporated under tlje

Companies Act and• having its registered office .at 304, Kanchtm House,
Karampura Comm.erci~t Compiax, New Dafhi-15, India, (hereinafter referred to as
lr.e "Madetra ConbuHdJLand Hoidlng Entll!l) which shan mean and include lts
$uccessors, admlnistrator, attorney, nominees and permitted assigns} of the
Fourth Part, capresented herein by its Authorized signatory Mr. Nitfn Gupta, 1
Precision, Blue Planet, G.lobal Estate & Madeira Conbuild Pvt. Ltd, hereinafter
co!lectively shall be referred to as Parties and individually as Party.
· \~
1 ,_ il . I
1it r~e ~la.net. Globai Estate and Madeira Conbul!d Pvt. Ltd. shall herelr.at!er. be
Ject:as Land Holding Entitles.
;1'
{A) ,, Preclsl<;ih Realtors/Authorized Asset Company intend$ to oonstruct aod

develop in collaboratlon with Land Holding Company commercial and
ll
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254
residential projects iA the revenue estate of vmage Dhumaspur and

Maldawaa Tehs!I and District Gurgaon.
(B) BltJe PlanetJ!..~nd. Holding Entity of the. $econ.ct Part is owner in

&xclusr,e po$.session of freehold •agrlcultora! land alongWith all vested
rights and !:!P-PUrtenant proportionate lnter~ts, situated in the revenue
estate of village Phuma.spur and Maidc1was rehsil aoo Olstrict
Gurgaon, the details whereqf are fuHy described In the schedule
annexed and marked hereto as .Annsxure.. 'A'.
{C} Global EstatE,1iland Holding Entity of the Third Part ls owner in

exclusive posses$ion of freehold agricultural land alongwith all vested
rlgl)ts and appurtenan, pr9portionate Interests, sfh.lat1ad In the revenue
estate of village Ohumaspur and Maidawas Tehsil and. District
Gurgaon, the details whereof are fully de~cribed ln the schedute
annexed and marked nareto <\lS Annexura~ 1B 1 •
l
(D) Madeira Conbul!d/1...and Holding Entity ()f fue Fo.urth flart 1$ owner In
exclusive possession of freehold agricultural !and alongwtlh al! vested
_rights i:li"id appurter:~nt proportl'J!ril'lte Interests, situated ln the re,venue
estate of village Ohumaspur and Maidawas Tehsil and District
Gurgaon, the details whereof are fully describerl in tha schedule
annexed and marXed hereto as Armexura-1C'"
, (E) The Authorized A$set Compaiw and Land Hold!ng Erttittes nave
agreed to jointly apply and obtain Licence., permissions, sanctions and
approvats ate. for their land hoidings as described in Anmuture A to C
(hereinafter referred to as "Schedut4:! Land" t.otai admar\s'urlng
37.5125 acres ($00 Jtanats 02 marla.s} fer the purpose of d◄veloping
an Integrated township, group Musing, plotting, · row 1 house$/
independent floors/ residential coiony/commereial/lT Park -etc, and
related developments. {hereinafter refe:trred to as the Proposed
7' Project} in accoidance with the rufes, regulations, bye laws; sitfictions,
permits, !fcances ·to be obtained from Director, TQwn and Country
,
Planning, Haryana and other competent authoritiEH.
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(F) The Parties further represent warrant &n(j assure that they have
absolute right$ to deal wit!'!, tr,ansfer or dispose of, av!hor!zei for their
r8$pective Jand holdings to be dev~!oped as Prcpos:e!d Project and
tl:tere Js no bar/restrlctioniimpediment for its intencteo use ;3nd
development from any quarters,
(GJ That the P~~ies hereto now wish to record and se-t out tha data!led
terms & conditions a,s app~aring hereinafter in this Addendum.
NOW, THEREFORE, THES~ PRE$eNTS WI.TNESSETH AND lT IS. HERl=BY

AGREED,
I
PECLARED, ANO COVENANTED BY AND BETW~EN THE
PARTIES A$ UNDER:~
1. That the I.and Holding Enfitles has agreed with Authorized Ass~t
Company to apply for the filing appl_icatlon(s) fur grant of Licence,
~rmissions, No objection Certificate and approvals. etc. and t~ obtain
all the statutory approvals required for development of the Proposed
Project on t~e Schedule Land from Oirectqr, Town and Countr1
Ptanning, Haryanc! and other cm71potont .au!horlt!es 1~ thl?, beh.a!t
2. That the land Holding Entitres heraby has authorized Precision

Realtors/Authorized Asset Company to act, represent ,?or and on its
behalf for obtaining various approvals, LOI, .Licences, submit scn.Htny
fee, licence fee or any other fee and deposit etc, or obtain sanctions
required for construction and development of the Proposed Project.
Th$ Authortzed Asset Comp:a~y has aeeeptad the authOri±atlons and
agreed to act for and on behalf of Landholding Entities for this Purpose,
For this purpose Lar:id Holding enijties has with this MOU has passed
resolution through its Board of Director'& to authorize Authorized Asset
Company.
3. The Authorized Asset Company ano Land Holding E: Uties represent

1
sAd warrant that:
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256
a) their respective holdings in the Schedule Land ls free frorr charge, lien,
mortg~ge, lease, tenancy, easement · rights, adverse posseasion,
tl.lstomaiy rt9ht~ 1 teqUisition, ~cquisition, equltabje interest, assignment
by way of se~ulity, no(iditionaf sales contract, !oan, arrears, t;ax,:,
outstanding, will, gifts, exchanges, security, agreement to sen,
collaboration, Mernora11durn of Understanding, joint venture, court
attachment, s~y order, family disputes, ti\\ilspassars, str¥ctures,
transformers 1 squatters. option, security interest, liability, place{s.} of
worship, hazardous mater/a~ pollutants,. undergroun(i{over head water
tanks, pipelines and transmission lines, water body{lei)1weus; or any
other proceeding or encumbrance ate of any kind.
b) All outgoings with respect to the Schedule Land suci) as land revenue
.ti!! the date ~!areqf have been paid in fulL However if any outstanding till
the date of these presents ll:; found It shall be promptly paid by the
respective owner/P~rty.
e) There are no disputes, actions, cf alms or demands by/with any Party or
owner or occupant of adjoining or neighboring land with respect to any
easement. right or means of access to the Schedule Land or ib use
arid occupation or in retation to ~ny neighboring property or rts use or
occupation, nor are the Parties aware of any circumstance that may
lead to the same and no notices affecting. the Schedul, Land nas been
given or received.
d} That, ½ithout preju~l~ to ,ts obligati0,'1s ln terms of the· preceding sub-
clause. the Land Holding Entities shall from time to tirne exec1.ite/further
authorize Authorized Asset Ct:impanr or its .appointed nominee,· as may
be required, !nteralia for change of land use ot the Schedule Lana,
making applications, obtaining of re<iuisite permissions, licenses an<i
permits anct,.submit or refund of fee for carrying on development over
the Schedule Land of a colony commercial and/or residential and other
fypes of real estate developments, demarcation, mutation of Schedule
Land, etc.
a) That the Parties to this MOU shall pay/centrtbute their respei;tive share
in proportion to their holding in the Schedule Land; for ;>,,nY fee, stamp
I
t
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257
duty) scrµtjny fee, external development charge, internal development

ch~rga, licence fee or any other levy required to be pafd or charged by
Director, Town and Country Planning, H~ryana or any other
statutory/competent authority, as may · b,e required for obtaining
requisite permissions, llcenses and permits for change of land us.e of
the Schedule Land and fQr carrYing on development oi' Proposed
F'roJect over the Schedule Land and other types or real estiata
developments .an'd would accordingly reqelve snare of profit i
compensation in proportlon to thalr holding In tf:te S~hadule Land.
fJ Without preJuclice to the forgoing, Parties hereto undertat<e to fully
indemnify each other against all and any losses, cc,sts, expenses
suffered and/or incurred by the other due to any misrepresentation,
defect in tifle of respective. holding or due. to any encumbrances over
the respective Mldlng in the Schedule Lana or ~my of the above
representation, warranty or undertaking being found irn::orrect. false or
unfulfi!!ed, at any time,
4, The Lanq Holding Entities have handed over-the copies of ownership
documents of its. r~specdve hoklinga In tho ·Schedule Land t~ the
AtJthorized Asset Company such ~s Sale Deeds, Jamabandis,
Mutations, Khasra Glrdawarls etc. and further undert:akes to produce
'
any fu.rther document or pr.oof of ownership of the Schedule i,.and as
may be required by the Authorl~ed Asset Company; from iime to tlrne
for purposes of obtaining license/CLtJ or any ?ther approval or sanction
. to be obtained from the regulatory authorities in Haryana and
elsewhere.
The Land Holdlng Entitles have ~greed that the Al.rthori:zed Asset
Company rnay nominc;tte or a~~lgn all and/or any of its rights and/or
obligations under this Memorandum of Wnderstanding to any third
person(s} / developer(s). Such nomination and/or assignment shall be
binding on the Land Holding l:ntitles,
6. That in the event of any flaw or defect in the title o.f the respective
holding in the Schedule Land or for any other re;;;son beyond the
I
\ 6
Jex,
. j
x:i +,,.~; i <...
es.-"~...@.
.
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. '!
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258
control of the Autnor!~ed Asset Company or any iforce Majeure'

clrc:umstance. the Authorized.Asset COrnpany is unable to get the CLU/
L~nse/ permission/ sanction for development of the Schedule Land
as agreed h~rein, or thl~ A~r(;loment is rendered impossible of
performance uoder ~fiy pfovision of law or dir.~ction of the. Stat~ Govt
or any other statutory authority(ies) of the St~te· Gavl or the Central
c;ilP.vt., ;any payments- received by A\Jthorized Asset Company from
umd Holding EntitieS., shall be refi.J.nded and paid back to the Land
Holding l:ntltles within a perlod of one month upon receipt of such
payments from statutory authorities, but without payment of any
interest or compensation.
7, That the performan~ of the. oblig~tiohs by the party of lhe Second Part
hereto under this agreement shall be subject to "FORCf MAJE.URE"
conditions, sQch as, earthquake, lightning, civil commotion, war, enemy
. '
action or any other similar circumstanqe pey~md the re~s()nab1~ ccmtrof
of.the Parties. In such an ~ventuatlty, the party of the Second Part shail
also be entitled to a reasonable extensi.or'l of time corresponding to the
8. That this Adctendum to MOU stian in no manner he construed as

creating any partnershlp or principal -agent reiation~hip bemeen the
Parties.
9. · That if any part of this Addendum .to MOU ls determined to be void or

unenforeeabie, the said part shall b~ deemed to have been amended
· or deleted ancl the remaining ·provisions of this MOU s.hal! remain
operal:fve provided those are capable of performance.
That any change, · modification or alteration or any ai11<,mdment,

whatsoever, in this Addendum shall be made only wtth mutual written
consent of the Parties hereto.
11. That all notices and letters shall be sent . through Registered post
Acknowledgement due to the other party at the adctniss(es) firet above
written or at such duly notified change of address ·
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259
12'. That all disputes and differences, arlsing out of or ln connec1ion with
this Addendum sl')all be attempted to be resolved mutually through
negotiations between aH the Partf~s failing which the same shall be
referred to and decided t,y an Arbitrator to be appointed from the list of
thre~ Arbitn;tors suggested by the mutual consent of all the parties.
The decision of the Arbitrator shall t)e final and binding i::,n the Parties.
The provisions of Arbitration & Reconciliatfon Act 1996 shall be
applicable to .such arbitration prooeedlngs.
·i 3, That the venue of arbitration shall be at Gurgaon or any other place as

may be murual!y decided upon between the P~rties.
14. The Schedule and the Annaxure form part of. this Addendum.
15. This Adden~um tq MOU shall be governed.by taws of India and shall
be subject to the courts at Gurgaon.
lN WITNESS WHEREOF, the Parties have caused this Addendum to MOU to be

duly axecut~d on the day, month ijnd yrsar first herein above written,
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For and on Senalf of:

For G!obal Estate
For anq Qll Sehalf of:

For B.h.ie Planet infrttd$V~ioper6 Pvt. Ltd.
p;.,) KU,;tl'f
b;c;0-11.l,V,~ '
1
·,
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261
IRRO &RAC£ 1Uttri.LT£CR PrulfATI! LIMITED

Rcgrl, O,ffice: • 304» Kanchan House., Ka.rampurn Commercial CompleA, New Delhi~1100:l5
Dated: 06.01.2020
To,
Sh Kamal Kohli
£OW Sec•lI/EOW1
Mandir Marg,
New Delhi-110001
·Sub; Notice u/s 91 C:r..P.C dated 2!5.06.2020 & 01.07.2020 regarding

investigation of cue FIR NO, 230/2018, U/8-406/4~0/ 120-B, lPC Moti
Na.gar ..received on 03.07.2020 at lnso Campus office at Sector 39,
Behrampur, Gurgaon •
This comprehensive reply along with related documents in response to notice number
3848 dated 01.07,2020, 2767 dated 25.06.2020, 3849 dated 01.07.2020 issued to Ireo
Grace Realtech Pvt. Ltd and 'Notice Number 2770 dated 25.06.2020 issued to Mr. Lalit
Goyal, is being submitted by Ireo Grace Realt~ch Pvt Ltd through its authorized person
in terms of board resolution dated 07.08.2019, having its business office at Ireo
Camp1,1s, Sector 59, Behrampur1 Gu.rga.on, Haryana,
The question raised hl all abovementioned notices are repeated, ::hua comprehensive
reply is being submitted;
1. Globru Estare is a Part."'len4~p Fh"'!l:l. Copy of Partnership d.eed fo annexed as

~nne.zu:re- l,
2. Global Estate is the Vendee/Purchaser in Sale Deed No, 14477. Payment details are
duly mentioned therein the Sale deed at page no. 2 and 3. The copy of the Sale Deed
no. 14477 is annexed as A.ml~.1,r:ure-2,
3. Global Estate is the Vendee/Purcha.ser in Sale Deed No. 5144. Payment details are
duly mentioned therein the Sale deed at page 4. The copies of the Sale Deed no. 5144
both copy of the original and certified copy from Office of the Sub ~egistrar, Sohna
are annexed a:s Aunoxurci-:.,!J (Colly).
4. That Precision Realtors Pvt. .Ltd , Maderia Conbu.ild Pvt. Ltd., Blue Planet
rnfradevelopers Pvt Ltd and Global Estate en~ereJ. into a memorandum of
understanding on dated 27.08.2010 for filing of application for grant of group
housing coloriy license for its land area in villages Dhurnaspur & Maidawas, Distt
Gurgaon before Director General, Town & Country Planning, Ha:rya.na. Thereafter
addendum dated 8.6.2011 to memorandum of understanding dated 27.8.2010 was
~xecuted to amend name of Global Estate as Partnership Firm (Copy annexed as
.~nqe;aure A-41, then again addendum dated 2L 10.2012 ......as registered in :which
inadvertently again Global Estate as Global Estate. company incorporated (copy
annexed as Annexure A-5t was mentioned. Further rectification deed was executed
as registered on 18.02.2013, where it was rectified that Giobal ]~state is Partnership
Firm. (copy annexed as ~:g~~~!)A,::'.t:>L All annexures A4, 5 & 6 are placed in records
in DGTCP Licensing file.
? £ ~ ~ ™ t..a.OU:L Az.W:3. ,;;...,... :;:;;:t,.;;w&L:?:;!f'_"..;'f,:}':'.ll_,,".:~1,!-':'!{:~~y.:;-~~+~~:~~!~~~~'S~?':'.?;;."";,,;\'.:;;±?~l?':'~,":~~'!?!:!'.""~~i:;:;:~;::?:s~.-..':,,"'~:,,;.""'·"''."."~~:";~•..,,,.,,,.,,.,,,:.,,"".,,....,,,<>;'c-";,..,...;,:,.o•/"."-0~
lludn!lat Addreu: Jrco Campus, Archview Drive, Ireo City, Golf Course Extension Road, (Jurgaon.J:221 Ol(Mnin Project Office)
CIN # U70200DL2010PTC202572, email id- igrpl@ireo.in, ?hone #91 0124 4795000
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IR.KO 6RJ\Clt REALTECB P·an/ATII lJMITRD

Regd. Office:• 304,. Kandum .House, Karampura C,lmmercfal Complex, New De!hi.!10015
$. Copy of bilateral. agreement with regard to License No. 5 of 2013 wht~rcin the bilateral
agreement is signed on behalf of Global Estate, a partnership fi:rm {Copy annexed as
Annuure A-71.
6. Copy of ocrupatkm .certificate dated 31.05.2019 for approx, 700 npartments in

Corridors group housi.."lg project (copy annexed as AnneXJ,IJt'II; ~:~). tt is submitted
that constn1ction at "The Corridors'" group houain.g project at Sector 67 A, Gu:rgaon
on land area admeasuring 37.512 acres has been completed. That construction of
1356 approx. apartments are completed, out of which 700 apartments in Towers A6
to Al0, Bl to B4, C3 to C7, EWS, convenient shopping, two le;rel basement, which
are ready to :move in, occupation certificate had already been granted on 31.05.2019.
Further to this application for gr<>-nt 0£ oc,ittpation certificate :for balance number of
apartments that is Cluster - A building num.ber A-1 to A-5, Cluster•B building
number B-5 to B-8, Cluster -C building number C~8 to C- l l, Community Centre,
EWS Building N0,2, Convenient shopping ~l (at ground floor of Building No. A-1)
Convenient Shopping-2 {at ground floor of building no, A-2} stands applied on
10,09.2019 and is expected to be granted soon.
7. That as per change in developer & change in beneficiary interest policy of DGTCP,
Hru:yana, Precision Realtors Pvt. Ltd has filed application for change of developer,
(Copy annexed as Ami~-;-~J~,:~l.
8. Copies of sate ,deeds along with list are annexed as ~nexure A-10 eoHv:
9. Copies of bank statement are annexed as An.nexu.r~ ~-ll;. cqUy,
Submitted acco:rdingiy,
Thanking YO}J.;.-""'
For ireo ~race ~Rffli)~,ch Pvt. Ltd..
Encl: Aa above
•~~-.i:~.....-.,,.""'!":""'-"'•~?~~'·:' l°l'.""'~•"."";,,»r1,,t.,..~~~~~~.,~:-•:"'"''"'"'_.",?''1/4i0,?t ;,,,;10:~~~~::~i.~;t.-:r:;~-..~~:•i•ut.~~~;;:;;.,•'~"'•,-c-,t•w~::..·"<••~.::~,.,,""'' ..,~q,,.:.,..,..<1•~:,•,•"'-'". •,·,

Buslll.69 Addre!!t: lrco Crm1p11s, Archview Drive, r;oo Cit'], Golrc~~$C bteu~onio;i;·Gurgiwn-12210l(Main Project Offi,;e)
CJN # U70200DL20l OPTC202572, email id- igrpl@lreo.in, Phone #91 Ot24 479SOOO
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~(/~\\
\ '\.,J'
F,lECTlflCATiON DEER
~} '• )v-,,hA' • >'
r::GW
·,,+,,,~p
r
TIUS RECTIFICATION DEED is made and executed at Gurgaon on this

fg ~ Februazy, 2013 ,· which is in continuation to original Memorandum of
Understanding registered before the office of the Sub Registrar, Gurgaon vide
vasika bearing no 22479 dated 21.12.2012 in Ba.hi No 1 ~ Jild No 13023 in
page no 7 and additional Balli No 1 1 JHd No 2591 and pasted in page no 9 and
1O> which was execut..ed among all the parties herein, and sl:ulll constittite pert
arid parcel oft.'l:te original Memorandum of Understanding as stated above;
Afy'IONG
Predtfion Re~lfo:rs .Pri'9ate Limited, a company incorporated under the
Companies Act, and having its registered office at 305, 3rd Floor, Kanchan
House, ICarampum Commercial Complex, New Delhi.. 110015, . India
(hereinafter referred to as the "Precision/AUTHORIZED ASSET
COMPANY" (which expression shall unless repugnant to the context or
meaning thereof be deemed to include its successom, administrator, attorney$
nominees and permitted assigns} Party of tbe First Part, represented herein
by its authorized signatory Mr. Ashok Chaudhary/ Nihkil Kinha..
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-::r: 26739
~ 0.00ffl ~~ · ~ ·q:ft ~ 10.00 ·~

'.'.~ 1:ft1 ·~ 10.oom t~~A Q <til ~ 0,00 ~ · ~ ~ 2.00'm
7.!J ~ ~ ~ 18/02!2013 m~ ~ 12:09:00PM ff ~/~.~ Precisi.cn Relilro~

~~/!:f.91" W / ~ ~ ~ 305, IDrd.Floor, K.8111:hanHoU!C, Karampwa Cmm:nercW Cornµie,t, Nt,,
D~Ll-tl-!WO!S i;Rf ~ tfI ~ fl:\;t,TT lfml
lit ?l'ed,fon Realti,rn Pw Ltd thru Nikhil Kin.ha( OTIIER)
·~ ~ ,ti~~ :t:nm:-Neeraj P!ffiffll' ~~ ti ·:it Jrvm ~ ~ ~ ~ ~ ~ •

'ii''lfT ~ ~ ~ ! ~ 1.fi' ~ 0.00 ffl ~ oo ~~ 'tR ~ ~
i1 ~ <1i'T ~ $ -tt ~ ~ ffll <Ft ~ 1'lftT .t *-" tr m ~ ftfim1
;;'nr ~ ~ ~ ~/~~ ·~~~ ~~~ ~ Ac:v. G~aoo
'4' JJil/~~ Katlin Singb.Joon ~ ~~A{rm't ~ Adv. Oi.trg.llOO ~ ~I
m1tfr i: 1 '.!fiT t+i ~ T$ ~ if ~ t1rr.rr ~ W "{;2 "l1TT ~ ~ t1
Ji
fl;:fq, 1~2(20D
~~~~1-0
~
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265
A.ND
Blue Planet Infra.developers Private Limited, a company inco:rpora:ted under

the Companies Act and having its registered office at 40/16, East Pa.t:::1 Na,gar,
New Delhi-110008, India, (hereinafter referred to as the "Blu;e Planet
Infradevelopers /Land Holding Entity'\ which shall mean and include ita
successors, administrator, mtorney, no~nees and penni.tted assigns), Party of
ti!!'! Sctond Part. represented herein by its Authorl.zed ·Sigaator,1 1'vfr, Ashok
G'haudhacy / Neeraj Panwar.
AND
Global E!tate, a Partnership Firm (hereinafter referred to as i•Ffrmr) having its
principaJ office situated at FA7/2, Okhla Industrial Arel½ Pha.'le-TI, De!hi-
110020, fadia, (hereinafter referred to as the "Global Estate n:..and Holding
Entity", which shall mean and include its administrator, attorney) and
p~rmitted assigns) Party oi the Third Part~ represented herein by its
Authorized Signatory Mr. Ashok Ch.audhary / Nccraj :Panwar.
AND
lVfaderia Conhui!d Pri"f·ate Limited, a company incorporated under the

Companies Act and having its. registered office .at 304, Kanchan House,
Kanunpura Commercial Complex, New Delhi-110015, India,. (hereinafter
x:eferred to as the ~Iaderla Conbuild /Land Holding Entity•~~ which shall
mean and include its successors, administrator, attorney, nominees and
pern:1it>.ed assigns) Party of the Fourth Part, represented herein by its
Authorized Signatory Mr. Ashok Chaudhary/ Neeraj Panwar.
Precision, Blue Plant, Global Estate & Madeira Conbuild Pvt Ltd. hereinafter
collectively shall be referred to as Parties and individually as Patty.
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266
Reg.No. Reg. Year BookNo.

26,739 2Q12·20B
~
~
Revenue Department lla¼"yarrn
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267
Blue Plant, Global Estate & Madeira Conbuild Pvt. Ltd. shat! hereinafter be
called as Land Holding Entities.
WHEREAS:
In the ori~al Memorandum of Understanding registered vide vaaika bearing
no 22479 dated 21.12.2012 in Bahi No l , Ji!d No 13023 in page no 7 and
additional Bahi No 1 1 Jild No 2591 1;1.nd pa:rted in page no 9 and 10, which
was executed among all the parties herein., the name of Global Estate, a
pa$ership Firm (hereinafter reterred to as "Firm") having its principal office
situated at E47!2, Okhla Industrial Area, Phase-II, Delhi-110020. was
inadvertently described as Global Estate, company incorporated under the
Compat'lies Act . This typographi".al and clerical error is recti:fied by way of
t
executing this present rectification deed. Now the name of Gfobal Estate, a
p8:,rtnership Finn shall be read as Global Estatet a partnership Firm
{'hereinafter referred to as ''Firm"') having its principal office situated at E4712~
Okhla Industrial Area, PJlase..TI, Delhi-110020,
THEREFORE, THES.E PRESENTS W1TNESSETH AND IT IS
HEREBY AGREED, DECLARED, AND COVENANTED BY AND
BETWEEN THE PARTIES AS UNDER: -
1. That the typographical and clerical error is rectified by way of
executing this present rectification deed. Now the name of Global
Estate, a partnership Firm shall be read as Global Estate, a
partnership Firm (hereinafter referred to as "Firmn) having its
principal office situated at E47/2, Okhla Industrial Area, Phase-II;
Delhi-110020, in the <>riginat Memorandum of Understanding
registered vide vasika bearing no 22479 date<i 2L12.2012 in Bahi No
1 • Jild No 13023 in page no 7 md additional Bahi No l , Jild No
2591 and pasted in page no 9 and 10, which was executed among all
the parties herein.
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268
Reg. Year Book No.

26,739 2012·2◊13
Nikiti1Kinha
'lfF.lli> C.L.Arom
wnfur:,r mt -::;rmr t f~ ·<r!f ~ ~""' 26,739 ~ H·ll'l"f> 18/02/2013 ?iiT ~ "i: l ~~ "l'1 13,028 ~
·7o ;: 12 ~ ~ f<wrr TTtTr ";l'l'/4 ·~r ~ m ~ ~ ~ 1 ~ 'l'f: 2,69J <ii'
~ ~ 77 "ff 78 ~ ~ ~ ! mf ~"ft ~n'f ~ ~ t ~ ~ · ~ ~ .il~llfH'!( SITT'
~ ~ ~ ~~ ~ ~ ~ ~ t, l
~ 18/02/2013
HARIS-EX
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269
2. AH other terms of conditions as stipulated in the original

Memorandum of Understanding registered vide vasika bearing no
22479 dated 21.12.2012 in Bahi No 1 ; Jild No 13023 in page no 7
and additional Bahi No 1 • Jild No 2591 in page no 9 and 10, which
was executed among all the parties herein shall remain same i valid
and binding among all parties.
3. This rectification deed shall be read as part and parcel of original
Memorand~ of Understaµding registered vide vas.ika bearing no
22479 dated 21.12.2012 in Bahi Wo l , Jild No 13023 in page no 7
and additional Ba.hi No 1 i Jild No 2591 and pasted in page no 9 and
l_O, which was executed among al~ the parties herein
IN WITNESS WHEREOF, the Parties have caused this rectification deed to

be duly executed O.Q the cl.av~ mo.nth and year first herein above ·written.
. ~~t1t:~Afil'i{;>
For and on Behalfot:
~'it,~IJC!Clltl
'· · Gu~or and on Behalf of:
For Precision Rca.~:rs Pvt. Ltd. For Madeira Conbuifd Pvt. Ltd.
~~- ~l
For and on Behalf of: For and on Behalf of:
For Global Estat8 For Blue Planet Indradevelopers Pvt Ltd
2.
KAA~i~,r;;cim
Advoca~IJ
Dist\. C½lufl:;, Q.;,', .,;,;,
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270
Name of the Nature 'Amount Period to Due Date of Remarks,

statute of the {Rs. in which the date payment lf any
dues lakh) amount
Income Tax Tax 703.2() 26 Aprfl, 2019

Act, 1961 Deducted (Rs. 396.29)
' at Source
rncorno Tax Tax day Various dat,,s

Act, 1961 Dedwcced
'following (Rs. t103,7? on
at Scum:
rnontt1 26 April, 20J 9,
Rs. 204~51 on
30 April, 2019
and Rs. 166. 90
on 27
S,?ptembcr,
2<H9)
'l.5th d;Jy Vi.!ril)\.lS date;;

Ernµioyecs' ofthc
Prc;ddent . follow:ng (Rs. 36. 79 on
fund$ And mont·i J.;: April, 201'l
Misci"!I ancous ancJ Rs. 35.8'J
Prc;v,sions on 15 April,
Act, 1952. 2019)
,.-,_,; ;:\-::ccn:L,~g t(~ tnfe;rrnation and ,::;xpianatior:s giver. to u~\ ~:!· 0 •jui:;s ou:st~H'H·.:'.'.·~:.: in r::-~"'.:;•~r-:"'
1
c,F
1rr.:ome.,,t-Qx a:1cJ ~;ervicc tax i:;1at have not been deposited \i\1tt:'1 t:ne Jppropr'.ntc i1u:-:-ionth:s
;iccow1t or any dlsrwte, are as foilow,;:
Ni:HIH! -Of, the Nature ofdues Amount (in Rs, Period to which Fonm1 where
Statute Lakhs) the amount dispute is
relate$ pendin·g
Act, Service Tax 174.69 200S.CJ6 :~o f:'X.f'.>Sf~

1.944 200'.HD and Service Tax
Apctiatc- Trtbunrti
!ncorrn:; Tax Act, lncon,e Tax 281.28 JO 3-1A Ccrr11::any '"JJ~;,.
1901 Lk:d hen ti on
for curn~ct1on in
Incomr; Tox Act, !•1ccm0 Tax 191.i,O th•? corr-putC!~.1:.;n
1961 o.: cc,JJdr'td
7014-1 '.i Tax
l:;.,,c:1r~::. ,jr1U borr:)•,v1n\J~i

Gi'.;Vi?.tn•:nr::r1t d ..,;c1n9 tt1r-~ \;'Jt}1;:;r1
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271
Particulars Amount of default Period of default

:as at 31 March. 2019
{Rs. In lal<h} · · · · ··
Ocfc:rred payrnent iiability 3,618.20 to 31 t:U10
inc1udin9 interest thereon
tow,m:is development chan,es
payabk) to the Government
!nsUtutions:
.,,,,.,,<, ''"'"'¥"•'' .
Standar(l Chartered Bc1nk

(Interest on loan)
Ind7a ii1i'offri,: ~iousing 739.17 November, 201'.:l to h::bn.iary, 2019
{Loan induding interest)
PNB Housing Financelimited 920.81 . October'. 2018 to March, :fo19
(Interest on toan)
. Jn<,llabt1ils i-i;;tis'fng,finance to ;-:,,arch, 20t9
Limited
Howevet, the Company has not (,Jefuulted in repuyment of dw,s to debenture-holders during th~
Yt1di,
ix. In our opinion and according to the information and explanat10M given to us, th(: Comp;:rny dI(1
not rnL,c moneys by way of initial public offer or further public offer (including debt mstrurncnts)
and die no( h<1ve any tenn loans outstanding during the year. Acccmlin~ly, t:ie of c.!ause
:l(ix) of the Order are not applicable,
x, To the t)est of our kn0\"1lcd9e arid acconJing to the rr:fonnatic:1 and -et<plart,,3tior;;,; ~i,1cn :~) ust nr;
rraud the Company or on th,, Company by its officers or ernploy(~es has lv~en noticed reportPd
dudng period cov-cn:d by otir atxd!t.
x; Ti~e nrnvisions of Sectior: 197 of the At:t read with Schedulc~ V to the. Act t'.!fC rot
Company since the Company is not a pubti,:; C0'11pany as defined under Scc~io:c
1\:::<:t;r,:Ln9!:.1{ provL::iCn$ of ct.nuse 3(xi) ofth~~ Or(..!cr &r~~ not s1p;,:P\~;J!;\ff:~_
xii. T1,,,Cmnpany b not a Nidhi Company. A.cr.:onlinyiy, pruvi.sions of clause· 3(xii) ,,r
applicable.
x111 lt, our opinion ond eccording to the inform£\tion and expl1.mati,,11s given to u;;,
th•'· rd,it:ed parties ac"n :n rnrnplia nee with Section 188 of UH? Act. .. whe• ,rnd
<\;:!Quis1te t1etatls have tJeen disclosed Hi the stanc1alone Jnct AS ;:1nftnci0i st:2nernetr~s
applicabl" accountirg standards. Since, tho Company ,s a pri'Jilte ,::ornp,,ir;y,
the provisions of Section 177 of the Act. are not applicable to the Cv1';;Jd;;v.
xiv. Dur:n9 the year, the Cornpany has not made any preforenU<Ji alicJtm::nt: or of
sh,ares or fully or partly convertible debentvres. ,\ccordingly. orr:visions
Ordnr 11m not applicable.
xv, 1n our i:;ptnlon and according to t!1e Infor:nation and expJi.u1ations ql\•t;n to !JS,, th:~ C<>rnpany ic:~
not entered into nny non-cash trnnsactions wtth the directors or pi::r-sons vvd;h ttl0rr 1
covttrf;-;'d und€r Section 192 of the t\<.:l. Accordingly, provisions J,1u:-;e J(xv/or 1
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272
Rof: PNBHFUCTL/CCB-i9/2017i8 Hl'l2.2017
Mis lreo Private Limited.

,1\. 1 ·i, •1s1 Floor, Nooti Bogh,
f\Jew Delhi -·J 10049
Subject:. Corporate Term Loan of INR 225 crnre to Mis. lreo Private Limited.
This is with reference to tile Joan appdcatIon of t,e cc1pt1011ec! proposal. I/Ve are pleasecl to
inform you that corporate term loan of !NR 22::, cro'"e to Mis kE'm Private Urnlti.C?d is sanctioned
subject to the foHowing terms and conditions,
··•·····T---·-- .. --····-······· ···---

/ Mis lreo Private Urni!ed (IPL)
smrCJyyi1Jsi E:.ntity . . . ... .... ............. ........
i l\t1/s. Aspirant Buiklers
Private Limited, Ws. Bulfs !~oaltors Private
Limited, Mis Commander Realtors Private LirnitecL Mis Fiverivers
'
J
Co-Borrowers
Developers Private Limited, iv1/s /,c:son Software Private Limited and
!. Mis. F'iyt3fiY§E'.'>I9V\itJ~!7lp
Txp§ o(F-_a_c_il_itv..___,_c_o_rp~I'°'t~ I E?r111_h9at1, ...
I loan Amount I INR 225 crore
!Tenure .... · · · · · · ! G0n19IJJhs inglL1d,i0gprincipc1: of 18 months.
! Rate of Interest I
! (Floating} i 13% p.a.
, l
}n,,
J Purpose
/' Fee
··~~·••···•··•·••',·
1. Immovable Properties
" fV1ortgage entire of lancl square meters

(25.:35 !oca:ecl at Suctor 58, Gurg210n. Haryana.
• Mortgage of land adme::isu:inrJ 23,067 square rneters (5. 70
Acres) located at Sect:;r Guroaon
(Minirnun, security co•1eraqe of 1.50 tirnes to be maintained during

the currency of loan)
Security
Hypothecation of receivables
• Hypothecation and escrow of future receivable:, frorn the project

"Plotted Development" of approxin1ate1y !NR 5f6.51 crore
(Receivable coversigc net of e>:penses of i 50 times to be

maintained)
• DSFM of INR 15 crnre equivalent of 6 rnontt1s of interest to be
maintained during the ct.1.r1·enfY...f'.Uoa11.- - -
/.{~P{hjpf; fFft ·iff?.Jr<•·L <:,idntu '!',,Fi, 2::l, «f-;,'f(l{~n '!ln ·,i F~(,,.,,A~ i WUJJ•i
Regd, Office: 9th Floor, Antriksh Bhaw;m, 22 l<asturba Gam111t Marq, New Deli11 • 110 001
Phone: Oll•23736BS7, Emni!: loans(,,)pnbllousinq.com, W!lb,it": w,v1N,pnbhousino.eom
CIN: U5S922DL198!IPt.C033856
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Additional Additior;a\interest @2°/c, per-rnonth 0~) delayed interelfltWlj;'fiE~r~jii'' I

1
Interest insfa,lrnents (Ca!c;uiated frorn due elate till the date of payment).
I Prepayment ff1e rnirlirl1Ll~Tl

jJJ\:1-f;aymen[ charge wil! be @ '.3l¼, of trk) loan -!
CharfJeS outstanding as on the date of pre-payrnent and sha!I be levied in cat;e
of migration of the loan to another inst1tut1on. There wiil t,e no
prepayment charges for repayment (fully or partially) of ban throuqh
own sources.
j I
I-Pre · ·
,.,,_,,f"""'""__ __
. Tega/reportsof thesecuritysi1aiiSe ob!aini;d from empanelled

· disbursement legal advocate.
" Minimum credit rating of 888- (Tripli:-) f:3 minus) of for oroposed
conditions exposure of INR 225 crom to be obtained rJefore dlsbursernent.
Clear, Marketable, Uncmcurnber-ed Title to the properties
p1 ovidod ai; security
• Enforceability certificate from the appointee! law firm/Internal
legal counsel.
Audited balance sheet cf 1PL as on 3!03.2017 to be provided
before disbursement ot loan and there s!1ould not be any
adverse variation of more than 10% ir the provisional vs
Audited as on 31,03.20ff /
Deposit of security documents to the satisfaction of PNE3HFL.
"
All loan documents shall o,;z, vetted by an empanelled advocate/
Internal Legal GounsHI before release of !oan arnount at
Borrower's cost.
. Board reso!u!ioni ;:,,uthority letter duly signed by all directors of
the IPL to ,:Mltl the loan from PNBHFL and authorizing a full
tirne director to execute dccurnenis.
11 Compliances required under the Cornpanles Act, l 956 and
Companies Act 20'1 '.3 for the borrov,1ings by a public/ pnvate
company.
• 36 Post-dated cheques from IPL each towaros debt obligation;
to be replenished 3 months before these ,:ire ext1austed.: beside
1-··;· ...,...... 9ne,_0l10,qu~_gLt9taJ !oan amo:,1ntJor 1~a9h fociHty. · ... ·•·
i Disbursement of CTL of INF~ 225 crore shdi! be donli., towards
i construGtion ancl clevelopnient of ongoinq pm;E,,:t subiect to nmv1ng :
I conditions ·
I
1. First tranche of !NH ·150 crore to be disbursed uptront towards :

construction and development of ongoin9 p:-r:iject ot !PL. ·
2. Balance !NF{ 75 crore sl1ali be disbursed only after downsizing of
the proposed loan through the sales proceeds of sale of licensed
land to Mis. Pacific Development Corporat!On Limited (PDCL) in
case !PL faiis to down s;ze the !oar: by INR ! 00 crore. b~1lance
sanctronecl amouni shail not be disbursed, ROI on disbursed
tranche of !NR 150 crore shall be increased by 200 basis points and
PN_!::l,l:lfL 5halil)?Ve n9r1t to rucoHtl1e loan 1
Other
ConcHtions IPL to downsize the ioaq of INF! 225 crrne bv lNR 100 crore
through the sak: proceeds of licensed a11cl pa~ce!/or any- ,,ther..,~1--;:·-~
sources 1N!lhin !2 monti,s from the da:e of f1•st disbursement'•;·,. '>
ln c;,1se of IPL's fails to do the same PNBHFL wHI have rigl;.{ftQ• ·•. .
r·ecall tr1e loan. ·. ~- ·.
rfr,fir,1,{i"T <hf1J\\;p1: gtjj i-1ftH,f, :Jidi\~JH 1Td'~t 22, £tt{i:f+ rfiFt) wrf. ·{!,, f~t<><{f t HJ001
Rcgd, Office: 9th Floor, s\ntril1sh 8hawan, 22 l<astmba Giln,H1i Mars, Nov, Oc,ihi · 110 00!
Phone: 011·23736857, Em<1H: lo,1t1,(<ilp11bhqu,in9.com. w,ibsit<J: www.pnbh(n1Sinq.com
C!N: L659:2lDL 198SPLC033856
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PNf3HFL reserves lheright-to-appoir1lsecurity ir~t&te,hffh'61'

expenses have !o be borne by the Applicant Company
PNBHFL's name should be displayed at conspicuous parts of
the site mentioning that the project is financed by PNBHFL.
CA Certificate to be submitted within a pericd of 45 days for
utilization of funds at each stage of disbursement.
Submission of tl,e revisecl approved plans of plotted
clevelopment project to PNBHFL within 3C days trom the date
of approval.
" In the event of not launching the plotted development project
within 18 months from the date of first disbursement, I PL shall
provide receivables ot any other project acceptabfe to PNBHFL
providing rninirnum receivabie coverage (net of expenses) of
1 50 times of the loan outstanding. In the 1:::vent of !PL no!
achieving any of above conditions, PNBH=L Ni!f right to recall
the loan.
Credit rating repo1i of lPL from external credit rnt;ng agency to
be submittec! within 3 months from the date o' becoming due.
HFC / Banl<ers are to be informed about PNBHFL's charqe on
U1e said project in case any TPA has been already signed by
the deve!oper for individual housing finance availed by the
prospective buyern. IPL to ensure that all the cases which have
been financed by other lending institutions, the rernaini11g
consideration are to be routed through PNBHFL's Escrovv
accounts only.
!PL wili inform aH the buyers of units sold/to be sold suitably
that the amount towards demand raised has b be deposited in
the designated PNBHFL Escrow accounts.
The receivables from so!ci cHld unsold units of ·'P1ott0cl
Devolopn;r:mt project" ::,re to be depositP.d in the des[gnatecl
Master ESCUJ\N Account. Master Escrovv accounts shall be
monito1·ed PNBHFL.
70'% of the receivables deposited into the rnaster escrovv
account froni me project "plotted development project" sh2,II be
deposited in designated RERA account and balance 30%, into
the escrnw account Any amount withdrawn from U1e RER/\
nccount shall M transferred to the escrow account. Collection/
receivables to be utilized towards construction of the project
ancl rep;;iyment of PNBHFL loan from the escrJw account in the
following ratio. Same should be compliance with RERA.
Distribution of
Distribution of cash
cash To !:)e utilized for
receivables
receivables
Towards debt
F-"'NBHFL
obligations
T owarcls construction
!Pl 20% and development of
project
H0gct Office: 9th Floor, Antriksh Bh,;:wv0n 1 ~~2 Kr:tsturtJa Gandhi MiH'g" NeVif DeH,i ,, 110 001
PhO!\l'.i: 011h2:5/3t:,e:5/, frnail: !ua,u~•Y'f.mbhQt.6ing,ccan, Webtfto: www.r,nhhou--.inq.-corn
CIN: L65922DL 1988PLC033856
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275
r, Lirni
use shall be n,onitored by way of CA cert!hcate. 1rlfil}p~~F!M~ffi'XF"I
for the principal repaid shall be given on monthly basis
u Stcinding instructions shall be issued to ll,e bankers for

rem•ttance of funds in the sharing ·atin to borrowers I
PNBHFL's respective current accounts.
The receivables remitted to the current account of the
borrower shall be utilized only for completion of the
project The receivables remitted to PNBHFL's current
acc:ourn sl-iaH be utHized towards payment of monthly
repayment of the proposed loans.
NOC for sale of plots of the project will he issued by
PM3HFL subject to escrowing of future receivables in
des;9naled PNB Escrow account ,ind maintaining
requisite security cover of 1,50 ti1res of the aggregate
of loans amount outstanding The amount repaid by
regular repayment I sharing mE,chanism will qualify for
NOC charge.
PNSHFL may charge towards NOC issuance to be
adjusted towards principal rep:::iyment in order to i
maintain security coverage.
Threshold Hrnit for the developer for withdrawal from escrow of
the project !PL ls !NR 50 crore (Including PNBHFL loan funds)
Unlit may (evise to the extent of loan repayment during loan
tenurn.
0 Re-conveytince of units rnmtgaged to PNBHFL shall be
effected only after the fulfilment of NOC condition,
" Builder buyer agreement shaH capiure rnort::1ag0 of project
PNBHFL.
$ PNBHFL reserves the right to sell units indi,idualiy & sevE::rally
1n the event of default
IPL to dit;dose in the Pamphlets! Brochuresi Buyer J\grnernent/
to publish in advertisement th0t the project land ls mortgaged
lo PNBHFL
" iPL vvill 0d1vely promote mdiv1dual home loans of PNBHFL for
its customers
Undertakinq fmm the Borrower
• Unclertaking that lPL shall provide sold and unsold ciata

certified CA for the project "plotted development project" on
half yearly r:,asis one the project is launched.
• That any tirne & cost overrun J shortf;;ill in this project to be
borne by promoters
" Thnt the funds brought in IPL the form of Equity / Capital /
Unsecured loans/preference shares/fuHv convertible
debenture in !Pl will not be withdrawn durin9.the currency of
PNBHFL loan (if any)
" Interest/coupon on unsecured loan/quasi capital/preference
share shall not be paict during the tenure cf the loan. However
the lll?z' b.e.. acc:ru~d . ---··
;,,11/i<A,1 9,1) :11,ri'i>\i ,,,Fl. 2::, ;;r,?[Y,ifl rr\,11 1,r1t ''1 t~<kfi -- 110nm
Rogd, Offic;;: 9th f'loor, Antriksh Bhmwm, n
l\asturba Gandhi Marg, N0w l)dhi - no 001
Ph<me: 01\·?.3l!.6!l:i7, Email: loanS.:,ipnbllousinq,com, Websito: www,pnbhou:,ing.com
ClN: l.65922DL!988PLC03385G
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276
nan
That c1i:irfr1g the currency ofp/;;J'BHFL loan
neiti-t~~11Rr~yFli~l5ffiijl'J
nor c1ny third-party interest would be created by them in respect
of the property where tile Pf\lBHFL funds are !CJ be uti!iLed.
That PNBHFL's lorm will not be used fo- any :.mautt1ur:L2d
construction I development on the project site.
• Proiect Receipts of "Plotted Deve!opmert Project" shall be
uWised only for ongoing projects only and PNBHFL loan
repayment as per the sharing ratio mentioned above. .
• Tt,at the, units already sold and to be sotd of the r,roJect
'Plotted develooment'' shall not be bouqht oack by IPI
ropayn1.en(offi1e proposed ioan shaii be clonE;ti1rougl~ 0truc'.urecl
payment mechanisrn as under:
l. [Viandatory downsizing of proposecl loan of lNR 225 crore by

iNR 100 crore within a period of 12 months fron1 the date of first
disbursement
2. Balance !NR ·125 crore sha!! be repaid in 42 oqunl pnnc1pal
instalment of !NR 2.98 crore/month after principal 11101atorit.m1
of 18 months. Interest shall be on rnonth:y cesi bc1sis
PNBHFL can review the casr1 flows PNBHFL mc1y accelera:ehnodify

the repayment schedule.
Validity of the
90 days from issue of sanction letter.
offor
General Terms & Conditions:

IPL wiH n,aint.sin debt to equity at less than :too
times during PNBHFL loan tEmure.
8. Cross Default Clause: In case the Mrrower I allied concernsi promoters oe:ault 1n
respect of any other loan availed from PNB HFL, then the account snail be cons:dered
111 def au!! and same is to be placed on alert/caution by c1ns0.
C M;,1teric1i1Aclverse Change Clause: If tMre is any matenal/aclverse change w,th ·c9ard
to d1vcrsifico.tion by the borrowor in to son1e other busrness/unreinted or
ciiversion of funcl/cr1,mge in management etc. prior perrn1ss1on 1st:::, be or:,t:; r:cd from
PNElHFL
D. Suitable undertaking from n1e borrower I guarantor/ company that std has
been flied by any bank/financial institution against them or any of firm/companies
in which they are partners/diredors/guarantors. Further, no account of the Borrower
Company/ group companies has been declared NPA/settied by giving rebat0/C)TS by
any banl,/H It is also to be ensured that none of the above oersons are ,n :)f the
caution/defaulter list
E. Tl1e borrower woulc! keep PNBHFL informed of the happening of the event iikedy to
have substantial effect on the profit/business or circumstances 21dversely tr1c
finanda! position of the company, its subsidiaries/ group companies/conwanies in
which it has invested, including any action taken by creditors agains' the said
comp::.mies, legaliy or othervvise,
F. PNBHFL's official or other authorized person of P1'lBHFL shall he to visit
the site and ca1T'y' out any inspection/ or examine the bocks of acco.mt till tik} currency
of the loan.
c:; F'NBHFL has the rigrit to alter or modify any condition or stipulate fresr1 condition
under intimation to company.
H. IPL wi!i comply for adherence of Natrona! Building Code (NBC)
;\jt[f~;;r !fZF•. 22, cfi\i/5·11 'i1,,i) 1 ,r{ ii;,:,;,ri 1101,11

ricncL Oifio,: 9th Floor, Antriksh Bhaw;m, 22 l<asturba Gandl1i Marg, N,::w !)<;\hi · no 001
P!lOll-¢: 011"2..31::56~5/, ernail: !of:tn~;.•,1·'.:'Pnhhou.::.in9,co,.r1, 'I.Nob.;ito~ wwv1.nnbhouslnq.com
ClN: L65922DL1988PLC033856
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277
formulated by Bureau o.f Indian Standards.

I. PNBHFL may at its sole discretion disclose any information to any institutlon(s) in
connection with the credit facilities granted to the borrower
J During t11e currency of the foan, the borrower shall not, wiihout the prior permission in
v,;rilinci:
Efh;ct any change in their capital structure. which may affect PNBHFL's interest
adversely.
2. Forrnu'.ate any scheme of amal9arnation or reconstruction.
3. Undertake 9uarantee obligations on behalf of any other borrower/or~ianization
other than whoHy owned subsidiary companies or associate companies.
4. Declare dividends for any year. if the account of the borrowin9 company with
PNBHFL is running irregular or if the company is in losses.
5. Sell. assign, mortgage, alienate or otherwise dispose or any of the assets of the
borrowing cornpany chargecl to PNBHFL
6 Enter into any contractual obligation of a Jong-term natwe affecting !PL's
financiaHy to a significant extent
7. Undertake any activity other than those indicated in the object ciause of the
Memorandum & Articles of Association.
8. Permit any transfer of the controlling interest or make any drastic chm1ge in the
managements set up.
9. Divert/ utilize our funds to other sister /associate /group con::;er.1.
f<. In case the bon-ower commits default in !he repayment of loan/advance or in the
Pf1yrT:em of interest thereon or any of the agreed instcilments of the loan on due
date; PNBHFL, CIBlL and/or NHB/Roserve Bank of lnd\a will have ;:;m ur1oua!ifieci
right to disclose or publish the names of the borrowing entity ancl its d,rectors as
defaulters in such manner and through such medium as ho comp21ny/RB!lNHB
in their absolute discretion may think fit
L Audited financials of the company has to be submittod within six months ot complelion
for each financial year.
Limited
W~\ M/s, lroo Private Limited, hereby confirm and accept t/1::: te1 ms 8., condit;ons i1erein
vvrftterr
/l.,1thorized Signatory
9c1r ,m,rd :.,i\lf'l'.r.1 ·•FT·!, 22. ,r,{~!;{<H ,J'M'l ,,riL ''l \i;,s;,\; l !0()\ll
fkgct. Offic.:.: Sth Flo,.:,,; l\ntriksh BhilWiln, 22 l(asturtn, (i;,n(fhi M,>rQ, Mow .)0fhi , no 001
Phon<>: 011·23736857, Email: loans,fbpnbhousi119.cum, Wobsito: •Nww.pnbhou·,ing.com
C!N: l65922DL1988PLC033856
\ 9 S
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278
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279
Ireo Residences Company Private Limited
Statement of profit and toss for the_year ended March 31, 2019
Note Year ended Year (mded

.. /1(). 31March,_20)c9 _. 31~...ill:!ih....2018
Rupees Rupees
Income
I other ,ncome 1,390,_0_J_Y_ _ __ 1,287,508
II Total Revenue 1,390,039 1,287,508
III Expenses
Decrease J {Increase} in Projects in progress l9 (298,601 155) (673,855,281)
Material cost and contractor expenses 217,667.860 597,2.77,7JJ
Employee benefits expense 20 72,230.73/ 75,357,797
Depreciation and amortization expense 11 63,27.9 98? 53,651,042
F•nanc:e costs 21 24,678,292 38,819,235
Other expenses 22 39 ,QSJ, 7 66:...--_____4;.;;9-'-"-Q8;c_Q;;c,c;_J_7~2C..
Total expenses 118,257,482 150,327,777
IV Loss before tax {ll- III} (116,867,443) (149,040,269)
V Tax expense
• Current: tax
• Deferred tax expense /(credit)
Net current tax expense
VI toss for the year {IV-VJ {74,435.310} ..... ,J139,938,918)
VII Earn.ings per equity share: 23

Norniwl vulue per equity share Rs.10 (previous
year e\S.10)
BE:lsic (7.9'.i) (14.9'.j)
Diluted {7/)S) (!A.95)
The aG.:ompanying notes,ant ,m 1ntegrn! part of U,e fina11c1ul statements.

As per our report of even date
Place: i.. ~,
Date:
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280
Date:
COLLABRATION AGREEMENT
rYPF-: or: UFTD CO[ J ,i\lW.A!lO~-l AC:RF

\/lt . r,.\CiF HF! IR,\f\Pt: R
I'EHSIL SOFINA
UfSTR/('T (il ;fHJ!\U\J
Ul'-,flS L.\i'-H> 71 K"\Si\i 7 \ 1!,\RI :\
f'YPF OF PRUP)·RTY
!Ri\NSi\CTlO~J :\ I T'. R~.
(4 l!f\,!ES OF Rs. r7
<::T1\\W D! ! 'i R::s. 0L-!l

IPY-\Sl FY (1 RCi,\O\
C)J,_!
).w··"'l .
;1-"
l l
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·,: •l;•z. 02 /03 /2 0281
l6
44J 48,000.00
Drafted Ry:
:{ampal Shnt1rn1 -:':,?.flTTl 4.\fl.Kn,hna N,"'.'·''

'1 :2 9TI U"f,-;:;H i!i<:ff /; I
i6
r. ...
,' t
"'ti , yi· - •Ti,·;
/
I
Revenue Departlm:nt !taryairn HARIS -FX "d( llSl
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282
COLLABORATION AGREEMENT
To be duly stamped and registered
This Collaboration Agreement (this "Agreement") is made at Gurgaon, Haryana on this 2nrt day cf
March 2016 ("Effective Date") amongst:
The Entities mentioned in Schedule 1 (hereinafter collectively referred to as "Land Owners or Project
Land Owners", which expression shall, unless repugnant io the context or meaning thereof. be deemed
io include their respective permitted assigns, successrs and liquidators) acting through their respective
authorized signatories, duly authorized vide board resolution in this regard, being F'arty of the FIRST
PART
(Such Land Owners being corporate entities have been auttwrizeo' by their respc:ctive hoarrJ resolutions
to execute this Agreement as summarized in Schedule I)
AND
!REO PRIVATE LIMITED, a company incorporated under the Companies Act 1956 8r.d having ,ts
registered office at A-11, First Floor, Neeti Bagh, New Delhi-110O49 (hereinafter referred to as "IREO'
wr1ich expression shall, unless repugnant to the context or meaning thereof, be deemed to mean ana
include its permitted assigns successors and liquidators) acting thro.1gh its authorized signalcry
Mr. Anupam Nagalia, duly authorized vide its board resolution being Party of the SECOND PART
ANO
HERITAGE MAX REAL TECH PRIVATE LIM!TED, a company incorporated under the Companies Act.
2013 and having its registered office at K-1, Green Park. Main., New Delh -1-10016 (hereinafter referred
to as "HMRPL". which expression shall, unless repugnant to the context or meaning thereof, be deemed
tc inc!uce it:, 8Ssigns successors and liquidators) acting thmugt1 its authorized sronatcr·1
Mr, Krrshan Kumar duly authorized vide its board resolution bQing Party of the THIRD PART
(f'dl parties to this Aqreement i.e. the Land Owners, IREO and HMRPL are hereinafter collec:t1veiv
r<:!ferred to as the 'Parties' and individually referred to as a "Party").
WHEREAS IREO AND LAND OWNERS HAVE REPRESENTED TO HMRPL THAT.
ORNAMENTAL BTVS 8UILDWELL AOSON SOFTWARE 81\SE EXPOFHS HERITAGE MAX

REALTORS PRIVATE LIMITED PF~!VATE UMITED PF:NATE LIMITED RFALTECH
PRlVATE PRIVATE
LIMITFD
GOLDEN HI ENERGY BULLS REALTORS COMMANDER !REO PRIVArE

VIEW REALTORS PRIVATE PRIVATE UMITED F~EALTORS PRIVATE
BUILDERS LIMITED Ufv'11TED
PRIVATE
LIMITED
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Reg. No. Reg. Year Book No.
3,687 20!5-2016 283
:\\1th Sign-i\nupam Nagafo
P:nv,m Kumar Shanna
'-------------------------------------··~--·-..... ,:' ~-c'.'i , ,'
HARIS-EX NlC-HSC
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284
A) The Land Owners are the owners of certain parcels of lands, which in aggregate forms a
contiguous parcel of land ad-measuring approximately 273 Kanal 4 Marla Le, approx. 34 175
acres in ViHage; Behrampur, Tehsi! Sohna and District GurgclOn in Sector 59, Gurgaon
(hereinafter referred to as the "Licensed Lands"), The Licensed Lands are mere particularly
described in Schedule-II to this Agreement and delineated on the plan in Purple and Green
colour, which is Annexure I. For the sake of clarity. it is mentioned :·,e,ein that the term Licensed
Land shall also mean the Rescheduled Licensed Land ( as defined herein ofter) under tt1e terms
of this Agreement and such Rescheduled Licensed Land is marked in the plan annexed as
Annexure n.
B) The Land Owners are vested with absolute and complete ownership an<i clear and marketable
title to the licensed Lands, free from any Encumbrance (as defined herein below) with absolute
and complete possessory rights and entitlements to the same The Lan::J Owners are reflected as
the recorded owners and as in possession of the licensed Lands in a!I governmental records
including the Record of Rights. The description of title and the ctment mutations in the Record
of Rights vesting the Licensed Lands in favour of the Land Owners are detailed in Schedule-VII
to this A.greement !REO has represented to HMRPL that certain portion of the Collaboration
Land was mortgaged in favour of Axis Trustees Services Limited and such mortga9es have been
fuily and finally removed and satisfied and as of the Effective Date there are no Encumbrances
over the Collaboration land and NOCs with regard to the same have been furnished to the
satisfaction of HMRPL
C) The Land Owners have granted absolute development rights to IREO in respect of the Licensed
Lands by and under the Development Agreements detailed in Schedule-Ill of this Agreernent
(the "Land Owners-lREO Development Agreements"). The Land Owners-!REO Oeve!opr:nent
/\greements have been duly executed and are bmd1ng and irrevoc.:ible in nature. There are no
facts or circumstances in existence and no events have occurred vvh,ch r-ender the Land Owners-
i REO Development Afireement void or ·voidable or repudiated er revoked or frustrated. or
of re:scisslon for any t\;:~1s0n. and in 11v;thout lirr-.:tzticn by reo::,on ~f k.1ck of
consideration, influence, coercion, duress, default. fraud or misi-eprt3sentation,
D} The Director Tow'n and Country Planning, Haryana CDTCP"} has granted tt1e following lJ1ree
licenses (together the "License"), wl1ich term includes any renewals ancf amenclments rnarJe to
the sarne from time to time) under The Haryana Development and Regulation of Urban Areas
Act, 1975 and the Ruies framed thereunder for development of group housing colonies on the
Licensed Lands:
ORNP,MENTAL BTVS BUIL.DWE.LL ADSON SOFT1N/\HF BASE XYOR1 S HE:RITAGI:: MA1'<
REALTORS PRIVl\TE LIMITED PR!V,'\TE UMITFJ) PRIV/,Tr: L!MiTFD f~FA! TFCH
PRIVATE PRIVATE
LIMITED UM!TED
GOLDEN Hl ENERGY BULLS REALTORS COMM•\NDEr~ lREO PRIVATE

VIEW REALTORS PRIVATE PRIVATE W/IITED RE1-\L TOf,{:S PRIVATE
BUILDERS LIMITED UMITED
PRIVATE
LIMITED
2 !' ,
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Reg. No. Reg. Yea.r Book No.
3.687 2015-2016 285
02!'0312016 cn'l
02/03/20!6
Revenue l)epartmcnt Haryana
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286
1
Group Housing ···License Area Date of Valid till
· S. No. J License Details (in Acres) Issue
l 31/1/2008
' '~,·""'""'-~'"~"
11 90 i 7/2/2008 1(3/02/20113
4.725 13/5/2011 i21os1201r
The lotal FS! currently available unrier the License on the Licensed Land as per tr1e norms set
out in the Zoning Plan is 2,443,133 sq ft ("Licensed FAR" or "Total Project FSI")
E) Out cf the Licensed Land, tand admf:asuring 6.712 acres as detailecl in :3chedule IV has t),-:Rn
acquired/earmarked for roads (the "land under Roads"), and land admoasuring 2. 708 acres
has been earmarked for community srtes including for schools (the "School(s)'} such land c,3l lec:
the ·school Lands", which shall also include a portion of the Land under Roads to access the
School(s) admeasuring approximately 0.28 acres marked in grey colour in the plan annexed ;.:is
Annexure Ii which depicts such School Land upon the obtainment of the re-schedulement of the
Licensed Land as discussed hereinafter.
F) IREO is developing various other projects and townships around the Project and also undertakin 8
infrastructure development works around the Project and selling units / saleable ar·ea in the said
projects.
G) IREO has obtained the approval for re-scheduling of the !and as currently comprised in the
License. at its own cost and expenses. in as much as certa1r adjoining lands wrll be/ have been
inte1 dmngcJd with some portion (equivalent in area) of the Licensed Land. The dimensions of thd
Licensed Land subsequent to such re-schedullng have undergone a change and requisite
approvals have been obtained by IREO from OTCP. ln addition. pursuant to such re-schedui1r~J
the schedules of the Liumse providing the details of th,? Licensed Land have also undergore
certain changes arid the sarne have beeri arnende<i by ietters!orders of DTCP as mcr,t;c,,c.::
herein below:
Of~NAMENTAL. BTVS BUiLDVJELL .t\OSON SOFTVvARE BASE E:XPOR rs HERITAGE MAX

REA.LTOHS PF{IVATf UMITED ?R!VATE L!M1TED PRIVAT!:: UMITED REAL TFCH
PRIVATE PR!VATE
LIMITED LIMITED
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GOLDEN Hl FN(:RGY HULLS REALTOf\S COMPv1ANDl:R iREO F'R!Vl\Tf'
VIEW f~E,\LTOF{S PHlVATE PRIVATE UMfTED REALTOR.$ PRIVATE
BU!L.DEF~S UMITED UMITFD
PRIVATE
UMITEO
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The dimensions of the rescheduled Licensed Land are as illustrated in Annexure ll hereof
''Rescheduled Licensed Land'') it is proposed that the Rescheduled Licensed Land has a
combined / consolidated zoning plan {the "Combined Zoning") and accordingly the Combined
Zoning shall be obtaired for the Rescheduled Licensed Land by IREO
H) IF~EO is also keen to gain best indust01 practices from other reputed developers, wl1ich wH! assist
in delivering good products in the market This wm also result in accelerating the process of
development. whict, IREO intends to undertake in the said area. Thus. IREO has been discussing
with HMRPL, whose promoters have the requisite expertise of undertoking and develop1n9
similar projects, for development of a part of the Rescheduled Uc.:,nsed Land, and 1-lMRPL has
accepted the offer of co!iaboration of lREO.
From the Rescheduled Licensed Land less the Land under Roads and School lands (tho
"Remaining Rescheduled Licensed Land"), !REO wHI make available part of the Remainmg
Rescheduled Licensed Land admeasuring approximately 8.9B7 acres (71 l<anals and 7
Mar!as), as detailed in Schedule V hereof for co~coliaboration with HMRPL, {hereinafter referred
to as the "Collaboration Land", and is coloured in green colour in the Rescheduled Licensed
Land Plan annexed as Annexure II) with the right to HMRPL to develop FS! thereon of 1.000, 000
(One Million) sq. ft (the "Collaboration FAR" or "FSI-Co!laboration Land') which development
shall include such services, facilities and amenities, as per this Agreement and may be required
to be developed on the Collaboration land and as permitted in accordance with the Applicable
Laws. It is provided herein for the sake of clarity that such Collaboration FAR has been calculated
in accordance witt: Applicable Laws and that in the event of any change or amendments to the
Applicable L.aws, !REO shaH ensure that such change or amendments do not affect the
Collaboration FAH in any manner whatsoever, save and except as under Clause 2.8 or tt,i:,;
Agreement
l) Tl,e Collaboration Land is a contiguous land parcel comprised within the Rescheduled Licensed
Land, The Col!aborat1on Land has a proper access through a proposed motorable sector rn2,d
having a ~vici!h of 60 tneters (vvith 12 rr:eter V✓ide service road). The C0Habor2tion Land is :-n:;:·s
particularly described in Schedule-V to this Agreement HMRPl shalt at aH times be entitled to
utilize and develop 1,000,000 (One Million) sq. ft of FS! (out of presently ava!lable FSi of
24,43, 133 sq ft on the Rescheduled Licensed Land) and develop 8.9'17 acres of land as shov,n
in Annexure 11 on the Collaboration Land, in the manner and on the terms and conditions a,,
agree(j in this Agreernent.
ORNAMENT /\L BTVS BU!LDWEU 1\DSON SOFTWARE: BASE EXPORTS HEJ,Z\T/\CF M/,X
REAL.TORS PRIVA 1 E LIMiTf'D PRIVATE UMiTED PRIVJ\ TE LIMITED RFALTFCH
PRIVATE PP.!VAfT
LIMITED UMiTE:D
GOLDEN Hi ENERGY RULL$ REALTORS COMMANDER lREO F'RI\//\TL

VIEW REALTORS PRIVATE PRIVATE: LIMITED REAL TORS PRIVATE L!MlTFD
BUILDERS LIMITED LIMITED
PRIVATE
UMiTED
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J) !REO (and its nominees) alone shall be entitied to the balance of the Rescheduled Licensed
Land Rescheduled Licensed Land (including Land under Roads ;;md Schoof Lands) less
Collaboration Land) Le. land admeasuring 25 258 acres (such balance land hereinafter called
the "IREO Principle Land", which is coloured in blue. brown, purple and grey colours. including
the area hatched under roads in the plan annexed in Annexure {I and marked in blue, brovm
purple and grey colours, inciuding the area hatched under roads ir: Annexure ll which depicts the
lREO Principle Land upon the obtainment of the re-schedulement of the Lrcensed Land) with
the right to utilize and develop the remaining FS! available of the Rescheduled Licensed Land to
the extent of FSl of 1,443,133 sq. ft, as per current regulations (such balance f".SI l1ereinafter
cafled the "IREO Principle FAR") on the IREO Principle Land
Kl IREO is already developing a part of the IREO Principle Land, being an area admeasuring 7.833
acres (previously 6.794 acres and subsequent to re-scheduling 7.c:33 acres) in collaboration with
another company with an FSI of 8,60,000 (eight lac sixty thousand) !5q. ft !and called the:
"IREO Another Collaboration Land" and the said FAR called the "mEO Another
Collaboration Land FAR"), !f~EO Another Collaboration Land is marked in brovm colour in the
plan annexed hereto as Annexure If which depicts the IREO Ancther C0Habora!1on Land upon
the obtainment of the re-schedulement of the Licensed Land.
L) IREO and HMRPL, with the Land Owners, have in accordance with the terms of this Agreement
agrcied to develop the Collaboration Land i.e. contiguous !and adrieasuring 71 K~mals 7 Mari<lt;;
(8.917 acres) subject to the conditions as set out in this Agreement.
M) NOW THEREFORE, 1n consideration of the mutual covenants, terrns and conditions ar·d
understandings set forth in this Agreement and other good an{j valw:1ble consideration. tr e 0
Parties with the intent to be legally bound hereby agree as follows
1, DEFlN!TiONS AND INTERPRETATION
•1 ·1 Definitions • !n this Agreement (including the recitals), un!ess the context othe,,,vise requires
the following expressions shall have the following meanings
(i) "Affiliate", shal! mean in relation to any Party, any person that cortrois. controlled
or is under the common control with that Party, as the case may be ancl shall !nciucie i!s
associates, group companies, parent ancJ subsidiary comp::iny(ies):
ORN1\MENTAL BTVS BU!LDWEU.. l\OSON SOFTWARE BASC EXPOfnS HEf~!T/:....Z.JE: lv1/\X

t'\FALTORS PRIVATE LIMITED PRIVATE LIMITED PRIVATE UMI TED RFAl.TECri
PRIVATE Pl'.{IVATF
UMITED UM!TFD
GOLDEN HI ENERGY BULLS REALTORS COMMANDfJ~ IR!:O PRIVATE

VIEW REALTORS PRIVATE PRIVATE UMITED RFAuoqs PRIVATE
8UILDEF:S UMITED Llr,11TED
PRIVATE
LIMITED
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(ii) ''Agreement" sha!! mean this Co!laboration Agreement ,nclud1ng all Scr1edule'.S and
,l\nnexures attached hereto or incorporated herein by refe,·ence, as may be amended /
supplemented by the Parties from time to time in writing;
(iii) ''Applicable Law" shall mean all applicable laws, bye-laws, rules, regulations, orders.
ordinances, notifications. protocols, codes, guidefines, policies, notic,::s, directions,
judgments, decrees. including the Foreign Direct Investment policies, rules ano
regu!;;itions and other requirements or official directive of any Govcrnmentaf Authority or
person acting under the authority of any Govemmentai Authority and/ or of any statutorv
authority in fndia, whether in effect on the date of this Agreement or thereatter and shai!
include all amendments, modifications, re-enactments anc replacements thereof;
(lv; "Approvals'', means and refer to al! permissions, indudin9 no ob1ect1on certificates.
clearances, permits, building sanction plans, sanctions, exemptions, app1ovals including
but not limited to Airports Authority of India, PoHutiori Control Bo;,rd, Ministry of
Environment & Forest Fire departments, BR-lll, Mining, Forest Araval!i clearance.
National Highways Authority of India, Ground water clearance. Haryana Urbar
Development Authority approvals, Tovm and Country Planning, local bodies buiiding plan
sanction t approval occupation certificate, completion certificate etc. er parts thereof
required from any Governmental Autllority or from any other per,;on, a:; tnn case may be.
for the acquisition, construction, development, ownership, occupancy oper8fon
management. disposal, transfer of or creation of third r;arty interest ancJ shall :nclude
without !imitation al! approvals relating to or pursuant to sanction of iayorn plans buildmr.;
sanctioned plans, environment, drawing of water, height, commencemen! certificates and
the occupation certificates required in relation to tt,e c:onstructior. development
occupation and sale of the Collaboration Land;
(v) "BuA' or "BUA'' shall mean built up area as per App!icab e Laws;
"Business DayH shn!! mean the day \~;hen the schechJed bark::; ar?_:,. 0p00 for (H 1hl1c
dea1ing in New Delhi and Gurgaon, Haryana in India.
(v,i) "Collaboration Land'' shall have the meaning ascribecl to 1t in H::c1t:,i H to tr:;s
Agreement
"Collaboration land-EWS Units" shat! have the meaning ascribed to 1t :n Clause 3 13 1

below;
Of{NAME:NTAL BTVS BUIU)WELL ADSON SOFTWARE BASE EXPORTS HERITAGE Mt,Y
RFAL.TOFI.S Pf<IVATE LIMiTFD PRIVATE UMlTED Pf"<.!VAfE. LIMITED REAL TE(>!
PF.ZIVAfE r:1F;1v1,.,rr
UM!TED LlMITFU
GOLDEN HI ENERGY BULLS REALTOHS C8MMAND[I~

VIE\N REALTORS PRIVATE PRIVATE LIMITED REA\.T0HS PRIVA TF
BUlLDEFZS UMITEO UM!Tl?:D
~'f:.:IVAT'E
LIMITED
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(ix) ''Collaboration Land Facilities" shall have the meaning ascribed to it in Clause 2 -1 s of
this Agreement;
''Customer NOC" shall mean any and all no objection certificates by whatever name ~md
as may be required under Applicable Law, from all current and future customers of Tota!
Project excluding HMRPL BuA for the purpose of exercise of HMRPL Rights and
performance of HMRPL Obligations or as other.-vise requin':ld t;:ider this AiJreement, the
cost of which will be borne by IREO;
(xi) "Definitive Documents" shall mean and refer to this Aqreernent, General Power of
Attorney, Escrow Agreements and other documents/agreements executed for the
Collaboration Land and the Project between the Parties;
(xii) "Density-Collaboration Land" shall rnerm the total density out of the Density-Licensed
Land that shall be available / utilized for construction / development over the Collaboration
land, being 3,562 persons unless higher density is available in respect of the
Collaboration Land under Clause 2,8 of this Agreement;
(xiii) "Density-lREO Principle Land" shall mean the total density out of the Density-Licensed
Land that shall be available / utilized for construction I development over the IREO
Principle Land, being 6,053 persons, subJect to such highec densily as may be available
in respect of the lREO Principle Land under Clause 2 8 of his .1\greement:
(xiv) "Density-Licensed Lane' sl1ail mean the total density available over the Rescheduled
Licensed Land, being 9,615 persons for the Licensed Land
(xv) "Development Rights" shall in addition to the natural grammatical meaning of the
expression also include
(a) all the rights and interests granted by IREO and the Land Owners in favour of
HMRPI_ under and in k,rms of this Agreement inc!uciin9 but not limited to rights to
develop the Project in the manner provided hercuwJer and rights iri tho HMHPL
BuA;
(b) irrevocable and exclusive rirJhts 10 HMFxPL to conrnence, carry out and
complete the development and construction of the ProJect on the
ORNAMENTAL BTVS BUILDVI/ELL 1\DSON SOFTWARE BASE EXPORTS HERITAGE MAX
REALTORS PRIVATE LIMITED PRIVATE LIMITED PRIVATE LMiTFD REALTECH
PRIVATE PRIVATE
UMITED UMlTED
GOLDEN HI ENERGY BULLS f~EALTORS COMr/1/\NDEf< IREO PRIVATE

VIE\/\/ REALTORS PRIVATE PRIVATE LIMtTEO REAL TORS PRIVATE
BUILDERS LIMITED LIMIT[[)
PRIV/\TE
LIMITED
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Collaboration Land, at its own cost and expense its agents, servants
or assigns, subject to necessary permission~ existing or future, from
municipal and any other concerned authorities and for tf,is purpose to l,ave
unhindered accGss to the CoHaboration Land including ingress and egress,
and do all activities for construction and development ti1ereupon,
(c) the absolute right to own, alienate, transfer, sell, convey or otherwise assign or
part with possession of the HMRPL BuA with proportionate and undivided rights
in the !and underneath and or other facilities at any time and to receive, retain and
appropriate air sale proceeds therefore frorn any prospective buyers/transferees
without !imitation or 1ien:
(d) the irrevocable and exclusive right to directly or indirectly transfer title 1n the
units/spaces/areas comprised in HMRPL BuA with proportionate and undivided
rights in the !and underneath to the prospective buyers, by execution of suitable
deeds and documents in respect thereto; and
(e) the irrevocable and exclusive right to maintain the Projec;t and pursuant thereto
the right to enter into agreements with purchasers, occupiers and owners of the
Units/Saleable .A.rca in the Project and to receive all service charges ard costs
from them without any limitation or iien.
(xvi) "DTCP" sha!! mean the Director General, Town and Country Piannmg, Haryana 01 such
designated competent authority to issue rene•,vals of License and buildin9 plan sanction:
(xvii) "ECC" shaf! rnean and refer to E!ectricity Connection Charges;
(xviii) "EDC" shail mean and refer to External Development Charges:
(xix) r:Effective Date•t shal; rnear; the date of rcg:ctrntiop t:f this
registration of the HMRPL GPA whichever happens later
(xx) "Effective Date of Escrow Agreement r ;;hall mean the date on wr1icr1 the payment up
to Stage-4 of Clause 5.1 under this Agreement is duty r0ceived by IREO;
(xxi) ''Effective Date of Escrow Agreement Ir shall mean ·:he date on which the payment
under Stage-3 of this Agreement being duly received by lf~EO,
ORNAMENT/\L BTVS BUI LOWELL ADSON SOFT\<VARE 8ASf r:XPORTS HERITAGE MAX
REALTORS PRIVATE LIMITED PRIVATE. LIMITED PR1\/A E: LIMrTED REAL TECH
PRIVATE PRIVATE
LIMITED LIMITED
GOLDEN HI ENERGY BULLS REM.TORS COMMANDER E

VIEW REALTORS PRIVATE PRIVATE UI\MTED REALTORS PRIVATE
BUlLDERS LIMITED UM!TED
PRIVATE
UMlTEO
8 !;
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(xxii) ;'Encumbrance" means any mortgage, pledge, equitable interest, assignment by way of
security, conditional sales contract, hypothecation, right of other persons, claim, secur:ty
interest, encumbrance, title defect, title retention agreement, voting trust agreement
interest, option. lien, ct,arge, commitment, restriction or limitation of any nature
whatsoever, including restriction on use, voting rights, transfer, receipt of income or
exercise of any other attribute of ownership, right of set-off, any arrang,ament (for the
purpose of, or which has the effect of, granting security), 01· any other security interest of
any kind whatsoever, or any agreement, whether conditional or otherwise to create any
of the same:
(xxiF) "Escrow Accounts" shall mean the escrow accounts op1':!ned and operated under the
terms of the Escrow Agreement land/or Escrow Agreement I!, as the casE~ may be:
(xxiv) "Escrow Agent!" shall mean the escrow agent as appointed by the IREO and HMRPl
pursuant to the Escrow Agreement I;
(xxv) "Escrow Agent II" shall mean the escrow agent as appointed by the IREO and HMRPL
pursuant to the Escrow Agreement fl;
(xxvi) "Escrow Agreement r shal! mean the escrow agreement enterej into by and between
lREO, HMRPL and the Escrow Agent I in relation to the IREO Escrow Account I and IRFO
Escrow Account II (IREO Escrow Account J and IREO Escrow Account If shall have /he
rneanings as ascribed to such terms under the Escrow Agreement I)
(xxv,i) "Escrow Agreement II" shall rnean the escrow agreement entered into by and between
!REO. HMF~PL and the Escrow Agent !I in relation to the HMRPL Escrow }\ccount
(xxv1ii\ · Escrow Agreements" shali collectively mean the Escrow Agreement I and Escrnw
/\green1cnt l: ·
(xxix) "Escrow Parties" shall rnenn the escrow parties under the Escrow /\grccments;
(xxx; "EWS Units" shal! have the meaning ascribed to it in Clau:,e 3, 13.1,
(xxxi) "FS!/FAR" means Floor Space lndexi Floor Area Ratio and is also used to denote the
area resultmg therefrom;
ORNAiv1ENTAL BTVS 8UiLDWELL /,0SON SOFTVVAf~E BASE ::XPOFHS HE:FZ!TACE MAX.
RE/,LlOFtS PRIVATE UM!TED PR!V/~TE LIMITED PRIVATE UMln=:o REAtTECH
PRIV!\Tfc PRIV!,TF
LIMITED UMiTF:D
GOLDEN H! ENERGY BULLS REAL TORS COMMANDER

VIEW i.'..!Et,l TOHS PRIVATE PRIVATE LIMITED REALTORS PRIVATE
BUILDERS UM!Tl:D LIMITED
PRIVATE
LIMITED
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(xxxii) 'FSI-CoUaboration Land" or "Collaboration FAR" shaH mean 1 000,000 (One Md!icn.,
sqliare feet cf FSI out of the Tota! Project FSI, and any addition/increase to the sarmJ in
accordance with the terms of this Agreement;
(xxx ii) ''FSI-IREO Principle Land'' or "IREO Principle FAR" shaU mean 1,443,143 square fe:f,t
of FS! out of Total Project FSI
(xxx;v} ·'Government Authority(iesf shall mean any government authority, statutory authority,
government department, agency, commission, board, tribi;nal or court or any other law,
rule or regulation making entity having or purporting to have jurisdiction on behalf of the
Republic of !ncfa, or any state or other subdivision thereof or any municipality, district or
other subdivision thereof, including any municlpalJ HUDNlocal authonty/DTCP having
Jur'isdictfon over any matter pertaining to the construction, development and sale of :r.,,
Project, Collaboration land and the IREO Principle land;
(xxxv) "HMRPL Account" shall have the meaning as ascribed tc it under th•e terms of U1e
Escrow Agreement ll;
fxxxvi) "HMRPL's BUA'' shan have the meaning assigned to it in Clause 4.1(ii) below;
(xxxvii) "HMRPL's Costs" shall mean any and all costs. charges. stomp duties, fees, expenses
or payments of any nature or description whatsoever, towards the following ·
(<,) J\ll costs and expenses to be incurred towards HMRPL Obligations under th!s
Agreement
(b) Towards compli<ince of obllgat1ons in tern1s of Clause 3. 3 cf this Agreement with

respect to Collaboration LandE\NS Units:
(xxxv'ii) "HMRPL Escrow Account" shali have the meaning as ascribed to the same under the
Escrow Agreement ii;
(xxx1x) ''HMRPL GPA' shall h;;:ive the rrn1aning ascribed to it in Clause 3 10 of this Agreement
herein;
(xi) "HMRPL Obligations' shaH mean the following;

ORNAMENTAL BTVS BU!LDWELL A[):SON SOFTv\lARE BASE EXPORTS rlERIT,A.GE MAX
REALTORS PRIVATE UMiTEO PRIVATE LIMITED PR!\/ATE UM!TED REALT[::CH
PRIVATE PR\VATF
IJM!TED LIMITED
GOLDEN HI ENERGY BULLS REALTOF{S COMM/\.N0ER

VIEW REALTORS PRIVATE PRlV,ATE LlM!TEO REALTORS PRIVATE
BUILDERS L!MlTED UMITED
PRiV/\TE
UMtTED
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(a) To construct and carry out development of the Coltaborat;on Land El/VS Units in
accordance with the terms of this Agreement and i'1 tt1at regard cornply with the
terms of the License, Approvals and all Applicable Laws;
(b) To incur all HMRPL's Costs;
(c) Not to do any act of ornission or comrrnss1on (in contravertion with ttHs
Agreement) in relation to the Collaboration Land that wou!d preJudice tr1t,
development or construction of the Collaboration Land, decrease the FSI- IRFO
Principle land or Density- !REO Principle Land or 1Nould have an effect of
withholding or denying permission to occupy the HMRPL's BUA, IREO's BUA or
the buildings/built-up area that may be constructed ::in the !REO Principle Land:
(d) ro construct and develop Collaboration Land-EWS Units in accordance with

Clause 3. i 3 below:
(e) To provide reasonable assistance to IREO in obtaining all Approvals, ,,anctions

and permissions, and renewals / extensions thereof, as may be requested
IREO for the Collaboration Land;
(f) To assist IREO, upon request being made by IREO, to obtain the Customer NOCs
by !l~EO of the Total Project (excluding Project), for exercise of HMF~PL F::ights by
HMRPL under this Agreement and the other Definitive Documents
(g) To assist in obtaining NOCs from the customers of the Pro.iect as may be requ:red
by IREO.
(h) To observe aii iaws, regulations and notifications dealing witr1 ;;;!/ the workers
f;ngaged for the dcveloprr:ent of t;;e Co!!aboratia:--i LaPd 1n 8C(~nrd;incr-; ',tvit('\ thi",
terms of this /\greement, including payment of their dues, wages,
taxes, benefits, claims, working conditions, safety, a,:cidents,
in respect thereof;
(i) To observe and shaH be responsible and Hable for all customersi allottees of any
units/area in the HMRPL BuA of the Collaboration Ltind and aH com:;:aints, cla1rns.
litigation made/initiated by them with respect to HMRPL's BUA
ORNAMENT/\L BTVS BU!LOWELL ADSON SOFTWARE BA.SE EXPOF:TS liERl"tAGE M,A..X
f::FNTOF~-S PFHVATE LIMITED PRlVATE UMITED PRIVATE UMI !ED REALTECH
PRlVATE Pf~IV/1TF
LIMITED t !tv1/TEO
GOLDEN Hl ENERGY BULLS REALTORS C0MM,\NDff~

VIEW REALTORS PRIVA.TE PRIVATE LIMITED REALTORS PRiVATE
BUILDERS UMITED LIMITED
PFZIVATE i
!IMITFD ',. &)
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(J) To be responsible and liable for all contractors, architects, consultants,

technicians, engineers, persons (including its own employees), brokers
advertisers, engaged for the development ot HMRPL's BUA inctuding payment of
their biHs, dues, salaries, fees, taxes, benefits, claims, safely, accidents
complaints, litigation :n respect thereof;
To maintain the Project·• including the Project Facilities t:I! l1and over of lhe sa:nc
to the association of apartment owners as per Apphi::abie Law;
(I) To enter into and exercise control over the Collaboration Lfmd for tt1e purposes of
implementing HMRPL Rights and undertaking HMRPL Obligations
(m) Not to consume FSl in excess of FSI-Collaboration Land or densr:y :r; excess cl
Density~Coltaboration land over the Collaboration Land, except as provided
under Clause 2.8 herein:
(n) To comply with aH the conditions contained in the Approvais as m.21y be obtained
from time to time in relation to the implementation of the HMRPL F:1ghts
(xli) ''HMRPL Rights" shall refer to the rights, powers, entitlements, authoritiE:s that HMRPL
would have to exercise the Development Rights and to undertake its obiigations an,.1
duti1:~s, as spedfied in this Agreement, with regard to deve!opmcmt of thi;, Coilaboration
Land and HMRPL Obligations and shall also include (but not be lirn:tecJ to) inter a!ia. ihe
fono\ving:
To enter into and exercise such control over the Co labmation Larni. as 1s requ1rea
tor implementing the HMRPL Rights and undertaking Hr1r'if~F'L Obi1gcition.s.
To plan conceptuaJ:z.e and design the entire Project;

1
To carry out the construction I development of tne Collabcrabcn Land ir:

accordance with the terms of this Agreement:
{d) To appoint, employ or engage architects. surveyors engineers. ccmt1·actors, sub··

contractors, labour, workmen, personnel (skilled and unskilled) or other persons
to carry out the devetopment of the Collaboration Land in accordance with the
ORNl',MEN1AL BTVS BUILOWEU. AOSON SOFTliVARE BASE EXPORTS HFRIT AG[ i\/11\/.
REALTORS PRIVATE UMlTED PRIVATE. LIMITED PH1Vi\TF UMllTD REAL.TECH
PRIWffE PFi.1\//\TL
LIMITED LIMITED
GOLDEN Hr ENERGY BULLS REALTORS COMMANDEf,

VIEW REALTORS Pf.;:IVATE PRIVATE LIMITED REAt.··oRS PRIVATE
BUILDERS LIMITED UMITFD
F'RIVATE
UMlTED
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terms of this f\greement and to pay the wages, rerruneration and salary of such
persons:
(e) To exercise full, free, uninterrupted and exclusive sale rights in respect of the
HMRPL's BUA in Jccordance with Clause 7 ? hen=:in:
{f) To make payment and/or receive the refund of all deposits, or other charges. fees
to and from all public or Government Authorities or public or pnvate L1tilities refating
to Project, Collaboration Area or pro-rated share as per Coliaboration Area;
(g) To calculate H1e Saleable Area of the entire Proiect;
(h) To exercise full, fre.e, uninterrupted, exclusive and irrevocable Development

Rights including but not limited to marketing, leasing, l:censing, transfer or sale
rights in respect of the HMRPL's BUA by way of sa1e, lease. license or any other
manner of transfer or creation of third-party rights therein including mortgage,
have exclusive control 1Nith respect to the pricing ot HMRPL.'s BUA and to retain
and appropriate a!! amounts tt1ereof for itself;
(i) To make applications to the concerned Government Authority or semi-

governmental authority in respect of Approvals including environment, levelling.
water storage facilities, water mains, sewerage, storr:1 water drains, recreation
garden, boundary waHs, electrical sub-stations, water and electricity connections
and approvals for cement, steel and other buHding materials, if any, as HMRPL
may deem fit, in tho event !REO fails to apply for the same within such time as is
considered reasonable by HMRPL;
U) To deal with, appear before and f1ie applications, declarations. certificates ar•d
submit/ receive information with, i.,s may be required under the A::ip!icabie Law.
c:1ny Government Authority as may be necessary for the development at the
Collaboration Land, in the event fREO fai1s to apply for the same within such time
as is considered reasonable by HMRF'L;
(k) To carry out ancl comply with all the conditions contained m U1e Approvals as may
be obtained from time to time in relation to the Project,
(!) To create mortgage (including mortgage by deposit of onginal title deeds) I

ORN/,MENTAI.. BTVS BUH.DWELL 1\DSON SOf'.TW/\F;f BASE C:<Prnns HERITN3L MAX
l~EALTOf{S PRIVATE LIMiTED PV~IVATE LIMIED PRIVATE LiMITUJ f,~EAL TE:CH
PRIVATE PRI\/Aff
LIMiTED LIMITED
Ir 1/
Iv
\,,.
C:,OLDEN HI ENERGY BULLS REALTORS COMMAND FR

VlEW RE/'-.L TORS PRIVATE PRIVATE UMITFD REAL TOf~S PR:VATE
BUILDEF-;S LIM!TED LIMITED
PRIVATF
LIMITE:D
&
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297
hypothecation I charge on the Collaboration Lam:1/HMl-::P!_ BuA I Net Sales

Revenue of HMRPL BuA from Project Collaboration Land or any part thereof for
raising construction finance for the Project and/or project working capital and/or
any credit/ loan facility and/ or for securing the refund of t!1e !FRSD by IREO to
HMRPL and/or to sc;,cure the performance of obligations of IREO and Lard
Ovmers under this Agreement and th~, Agreement/Definitive Documents:
{m) To sell, transfer, assign all benefits, nghts and obligations ns contained herein (in
whole or in part) including HMRPL's BUA to any third party, at its cost risk and
expense and to retain all amounts thereof for itself, provided always the benefits,
rights and obligations as contained herein can be assigned by HMRPL to any third
party and the HMRPL's BUA can be sold f transferred to any third party;
(n) To advertise, launch the Project for sale of HMRPL's BUA .
(o) To execute ail necessary, legal and statutory wntings, agreements and
documentations for the exercise of HMRPL F{ights and HMRP! Obligations anci
in connection with 811 the marketing and sale of HMl'.;;PL's DUA, and require !REO
and the Land Owners to do the same.
(p) To manage ar.d maintain the Pmject!Col\aboratio 1 Land and the prop(~rty and
facilities / common areas construded upon the Collaboration Land as may be
required under the Haryana Apartment Ownership Act. i983 or any other
Applicable Laws and/or rules made there under and / or to transfer/ assign right
to maintenance to any third and to collect and retain all tienefits, charges, fees,
security deposits, amounts from the nllottees / pwchaser of the entire Saieable
Area of the Project;
(q) To consume FSI and density over the Collaboration Land up-to the FS/,
Collaboration Land and the Dens!ty,Coll?boration Land and any additional FSI
available under the TOR. or any other scheme as agreed under the Agreement
and in accordance with Clause 2 8 of this Ag~eement;
(1) To take steps and all actions which may be required fo1 seeklng the Change in
Beneficial lnterest Permission in favour of HMRPl from the DTCP or any other
concerned authority,
ORNAtv1ENT AL B1YS BUiLOWELl ADSON SOF1 WARE BASE DZPORTS HE:T-<ITAG[: MAX
REALTOHS PRIVATE UMITED PRIVATE UfvHTFD PRIVATE LIMITED f~EALTECH
PRIVATE PRIVr\TE
UMITEO LIMITED
GOLDEN Hl ENERGY BULLS REALTORS COMMANDER \REO f;RIVATE

V!E\AJ REt'\LTORS PRIVATE PRIVATE UM11TD REt\L TOR~; PRIVATE Uii.llTED
BUILDERS UM!TED UMITED .i
PRIVATE
L!MfTED
&
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298
(s) To take appropriate actions, steps and seek cornpfomces, approvals and
exemptions under the provisions of the Applicable Law. and
(t) To generally do any and all other acts, deeds and things that may :::ie required for
the exercise of the HMf~PL l~ights and performance of HMRPL Obligations anu
as more elaborately stated in this Agreement, and L:ndertake all such acts, deeds
and things in respect of the Collaboration Land that rnay not have been specificaily
dealt with in this Agreement
(u) To appoint maintenance agency and form the association of the buyers/owners of
the Project
(xiii) 'IBMS' shall mean Interest Fkiaring Maintenance Security:
(xliil) 'IDC" shall mean and refer to Infrastructure Development Charges;
(xliv) IFMS' shaH refer and mean to Interest Free Maintenance Security;
(xiv) ''IFRSD or Refundable Security Deposit" shall mean the amount aggregating to
Rs. 4,299,000,000 (Rupees Four Hundred Twenty Nine C'"ore and Ninety Lakh only) tu
t)e paid by HMf~PL to IREO in terms of this Agreement as interest free refundable security
deposit;
(xlvi) ''!REO's BUA" shall have the meaning assigned to it in Chause 4.1 (i) herein;
(xlvii) '·!REO's Costs' shail mean any and al: costs, charges, stamp duties, fees, expenses or
payments of ory nature or descnption whatsoever, towards the following •
,'.a) towarc!,3 iPFO Obligations under this Agreement;
(b) tm,vards compiiance of IREO Obligations of obtaining any Approval required ir;
of the Total Project as mentioned in terms of this f\,;:ireement;
(c) towards compliance of IREO Obligations to obtain any re-approval. renewal

extension or modification of any Approval in respect of the Total Project in terms
ot this /\greement
ORNAME~~TAL BTVS BU1LDVVELl c\DSON SOFT\NARE BASE EXPORTS HERlTACE ro.x

REALTORS PRIVATE UMITED PF/i\/ATE LIMITED PRIVATE urv,!TED REAL.TE Cf.,
PR.IVATE PRtVATF
LIMITED LIMITED
GOLDEN BULLS FEALTORS COMMANDf=R !RF:0 PP.I\J,t.ff

VIEW REAL TORS ?F:IVATE PRIVATE LIMITED REALTORS PHIVATE
BUILDERS llMiTED urvHTEO
Pf~I\J,C..lf
WAITED
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aH taxes, cesses, iand revenue payable to the concen1ed authorities in respect of

the Rescheduled Licensed Land during the constructton ;;md implementation of
the ProJect,
(e) all applicable taxes under /\pplicab!e Laws of any nature whatsoever which m81'
be attracted for the sale of IR.EO'S BUA including but not limited to applicable
Service Tax, VAT and GST
(f) Towards the construction and developmer:t of the Rescheduled L,censecl Lanci
Facilities and the Collaboration Land Facilities
(x!viii) "IREO Escrow Accounts'' shall co!!ectlvely mean IREO Escrow Account l and lREO
Escrow Account l!:
(xlix) "!REO Obligations'' shall mean the foHowing:
{a) To incur all fRE:O's Costs;
Not to do any act of omission or commission in relation to the IREO Principle Land or
otherwise that would prejudice the development or construction of thf: CoHaborat:oc
Land or would have an effect of withholding or denying permission to occupy the
Ht,J!RPL's BUA or lREO's BUA:
(c) To construct and develop !REO Principle Land, EWS Units, Rescheduled Licensee
Land Facilities, Collaboration Land Faci!ities and Sch()ol in accordance with terms of
this Agreement and ;n that regard comply with the terms of the License, Approvals
and a!i Applicable Laws,
To apply for and secure an Approvals in respect of the Project in a timely manner anc!
cts rnay be ;ecuired by Hl\lRPl
To deal with and obtain NOCs, if any required, trom Mahindra Homes Pvt Ltd. at its
own cost in order to fulfill U,e lREO Obligations and free exercise of HMRPL Rights
by HMf::;PL:
To obtain. wherever necessary, Customer NOCs. for exercise of HMRPL Rights by

HMRPL under this Agreement and the ott1er Definitive Documents
ORNAMENTAL 8TVS BU,LDWELL ADSON SOFTWARE BASE EXPORTS HER!T AGE Mt..X
F{EALTORS PRIVATE WAITED PRIVATE UMiTE0 PRl\,'ATE LIMITED REALTFCH
PRIVATE PR1VATT
UMffFD UMITEC':
GOLDEN HI ENERGY BULLS REALTORS COMMANDER

VIEW REALTORS PRIVATE Pf<lVATE LIMITED REALTORS PRIVATE
8U!LDE:r~~: UM!TED UM!TEO
PRIVATE
UMITEO
&
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300
{g) To maintain the norms for FSl-lREO Principle Lane ard Density-I ~EC
Land as prescribed in this Agreement:
(h) To irrevocably permit HMRPL to enter upon and e;<erc1se such control over the:
Collaboration Land as required for the purposes of Hxercising the HMRPL r~ights
and collaborator land development obligations:
(i) To require and make Land Owners to transfer title 111 Saleable Area of HMRPU:
BUA and !REO'S BUA and the proportionate share n Collaboration Land, in favor
of the ailottees of the HMRPL's BUA and !REO'S BUA and to execute all
documents thereof in a timely manner in accordance with tr·e contracts i
arrangements between HMRPL and the a!!ottees / purchasers ,RFO and the
allottees/ purchasers at the cost, risk and expense of HMRPL;
(D To execute a!! necessary legal and statutory 'ft1ritings agreements and documents
1
for exercise of the HMRPL Obligations and HMRPL. Rights and "or sale of the
HMRPL's BUA and IREO'S BUA as and when and in U,i.J manner I format that
may be required by HMRPL, and to require the Land Owners to do the same;
(k) To maintain unencumbered title I ownership of the Land Owners on the

Collaboration Land:
(i) To refund the Refundable Security Deposit to HMRPL in accordance with Clause
5 of this Agreement;
To ensure that the HMRPL GPA provided 1n accorcance with Clai.;se 3 HJ of trw;
Agreement and authorizations that may be provided in furtheranci~ to Other
Documents subsist and continue at all tirnes:
(n) To observe at all times all laws, regulations and nctifications deaimg w,th all tt1e
workers engaged in relation to development work pursuant to the IREO
Obligations, inciuding payment of their dues, 1;,ages, gratuity cess taxe~;
benefits, claims, working conditions, safety, accid,mts complatnts :n
respect thereof;
(o) To observe and be responsible and liable for all customers/ aiicttees of ,,iny
ORNAMENTAL BTVS BUILDWELL ,1..DSON SOFT\NARE BASE EXPOFns HER!IACE MfaX
PEAi.TORS PRIVATE UM!TED Pf'.;llVATE LIMITED PRIVA'E LiMITED RF1\LTECH
PRIVATE Pf"::V/,TF
UM!TE.:D
GOLDEI\! HI ENEf{GY BULLS REALTORS COMMANDIR

VIEW REALTORS PRIVATE PRIVATE UM!TED RE.6-LTORS PRIVATE
BUILDf::RS LIMITED UMITED
PRiVATF
LIMITED
&
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units/area with re:spect to IREO's BU/\ 1n the Collaboration Land ancl all
complaints, claims, litigation made/initiated by U1em 1n relation thereto
(p} To be responsible and liable for an contractors, consultants, technicians,

engineers, persons (including its own employees, brokers, advertisers) engaged
for in the development work pursuant to the IREO Obligations including payment
of their bms, dues, salaries, fees, taxes, benefits, claims, safety, accidents,
complaints, litigation;
(q) To provide full assistance to HMRPL, at the request of HMRPL, w manage the
Collaboration Land and the property and facilities .' Common Areas constructed
upon the Collaboration Land as may be required under the Har:1ana f\partment
Ownership Act, 1983 or any other Applicable Laws and/or rules made there under:
{r) To comply with al! the conditions contained in the Approvals as may be obtained
from time to time in relation to the implementation of the iF<EO Obligations
(s) To comp1y with all other obligations as stated in ttw, Agreement.

(t) To construct and develop the Rescheduled Licensed Land FaCJiities and
Collaboration Land Facilities at its own cost and expense in acco•·dnnce with the
terms of this Agreement.
{!) "IREO Principle Land" shall have the meaning as ascribed to such. term under Recital J
hereof;
(Ii) "IREO Principle Land Facilities'' shaH have the meaning ascribed to 1t 'n Clause 2.7 of
this Agreement
'!REO Principle Land,.EWS Units'' shall have the meanin3 ascribed to it in C.121,cs,;;, -~ ·1 1
beiow:
(liii) ''IREO Project" sha!i mean and include development of the following on the IREO
Principle Land as part of the Proiect;
Plotted and/or Residential group housing andlm any other construction and
development whatsoever permitted by Applicable l",w or permissions from
OFlNAM[NTAL f3TVS BUILDWEU. ADSON SOFTWARE BASE EXPORTS HE:RIT AGE MAX
REALTORS PRIVATE LIMITED PRIVATE UMITED PRIVATE LIMITED R[:AL lT:CH
F'F{tVATF PR:VATE
LIMITED UM!TED
GOLDEN HI ENERGY BULLS REALTORS COMMANDER lf~EO PRiVATE

V!EVV IU::ALTORS PRIVATE PRIVATE LIMITED REAL ORS PRIVATE
BUILDERS LIMITED L!MlTFD
PRIVATE
UMiTFO
I
I
&
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302
appropnate Government Authorities; by consurning FSI-IRFO Principle Lane.

Density-lREO Princip!e Land and Addihonal FAR (as defmeci hereinafter)
(b) Such number of car parking spaces as are required to be provided for the number
of dwelling units that may be constructed on the !REO Principle Land and as per
the norms set out in the Zoning Plan,
(c) IREO Principle Land-EVVS Units;
(d) Infrastructure development specific to the IREO Principle Land,
(e) Development I construction of School in accordance with Clause 2.20 below
(Ev) ''IREO Receivables" shall mean and include any and all revenues and proceeds on
account of sale/ transfer or other disposal in any manner of the interest in any phase/part
payable by the a!lottees with respect to any allotment out of the lf~EO BUA, including but
not limited to any advance bookings, earnest money, EDC/IDC, preferential location
charges, parking, clubhouse, power back up, interest, transfer fees, cance!lation/forfeiture
amount, Other Statutory Charges, or any other charges thar: are recovered or recoverable
from such allottees;
(Iv) ''IREO Rights'' shall refer to the rights, powers, entitlements, authorities that I REO would
have to undertake for the discharge of its obligations and duties, as specified in this
Agreement, with regard to IREO Obligations, i.e. the foHowinr.r
(a) To carr1 out the construction / development in relation ;o 111e iREO Obligations:
(b) To appoint, employ or engage architects, surveyors. engineers, contractors, sub-
contractors, labour, 1ivorkmen, personnel (ski!leci and unskilled) in the manner
specified in Clause 3.5 below or other persons to carry out the development in
relation to the !REO Obligations and to pay their foes, consideration, ·Hages,
remuneration and salary of such persons in a timely manner;
To exercise fuU free: unir:terrupted sr:d exc!cs!ve sale~ rights in r'~Sf)PCf of th~
1
IREO's BUA in accordance with Clause 7.2 herein.
fd) To make applications to the concerned Governrnen: Authority or semr-

governmental authority in respect of Approvals required fer the Project;
(e) To make payment of all deposits, or other charges 1ees to all public or
Government Authorities or public or pnvate utiiitie,s, that rnay have been paid I
ORNAMENTAl_ BTVS BUllDWELL ADSON SOFTWAf1L BASE EXPOrns HERITAGE MAX
REAL TORS PRIVATE LIMITED PRIVATE UMITFJ) PRIVATE UMITED REALTECH
PRIVATE PRiVATE
UM ITEO UMiTEU
GOLDEN Hl ENERGY BULLS REALTORS COMMN-JDER IREO PRIVATE

VIEW REAL TORS PRIVATE PRIVATE LIMITFD REALTCRS PRIVATE
BUILDEF!S LIMITED UM!TEO
F'R!V,t.1.TE
LIMITED
l9 "
&
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303
deposited by IREO;
(f) To deal with, appear before and file applications, declarations, certificates and
submit/ receive information with, as may be required under the Apphcab!e Law.
any Government Authority as may be necessary with ~especr to Approvals relating
to the Project and implementation of the lREO Obligations:
{g) To carry out and comply with all the conditions contained in the Approvais as may
be obtained from time to time during 1mplementation of the !REO Obligations:
(h) To execute all necessa1y legal and statutory writin9s, agreements anc
documentations for the exercise of !REO Obligations and ,n connection with the
sale of fREO's BUA; and
(i) To seek co-operation from HMRPL generally to do .3ny and ali other acts, deeds
and things that may be required from time to t1rne in respect of and for the
development of the Rescheduled Licensed land Facilities /Col!aooration Land
Facilities; and
(j) Generally, to do any and all other acts. deeds and things that may l:ie required fix
the performance of the IREO Obligations
(lvi) "Land Owners-!REO Development Agreements" shall have the meaning ascribed to it
in Recital C to this Agreement;
(!vii) "Lender" shall mean a third-party lender funding the development or construction of the
CoHaboration Land or providing any refinancing facility thereof,
(lviH) "License" shall have the meaning as ascribec to such term under Recital D of this
Agreement;
(!ix} "licensed Lands'' shaH have the meaning ascribed to it in Recitai A to this Agreement;
(Ix) "Net Sales Revenue" shall include the basic: sale price, the prekr,mtial lccation charges,
car parking charges, club t,ouse membership chargt1s, power b8ckup charges, transfer
fees, cancellation charges, interest on payrne1ts ar:d al! such other similar
charges that can be retained by a developer I promoter of a of a similar nature It
ORNAMENT AL BTVS BUlLDWELL ADSON SOFTWAf;;E DAS'0 [:X,PORTS HE:RITAGC MAX
REAL TORS PRIVATE UMITED Pf'.{IV.l\TE ur111ITFD PFUV,'.\TT !. . lt✓1:TED REALTECH
PRIVATE PRIV/,TE
LIMITED , UMiTFD
Vr-
GOLDEN Ht ENERGY BULLS f~.E:AL TORS COMMANDER IREO PRIVATE

VIEW REALTORS PRIVATE PRlVATE UMiTED REALTORS PRIVATE
BUILDERS LIMITED LIM!T!·•D
PRIVA,TE
UMITED
&
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304
is, agreed between the Parties that alt IFMS, IBMS ECC, EDC and IDC witr1 regard to tr,e
entire Saleable Area shalt belong to HMRPL, and lREO undertakes to c!eposit Other
Statutory Charges in relation to lREO's BUA with the relevant Government Authorities as
per Applicable Laws,
(!xi) ''Other Statutory Charges" shall include service tax, VAT and all other similar charc:;cs
including GST that may be applicable/made app!icable/ri::iquireci to be transferred ;
deposited to a Government Authority in the process of allotment / sale of the SaterJble
Area in the Colfaboration Land:
(lxii) ''Other Documents" shall have the meaning ascribed to it ir Clause 9, ·1. 1 below;
{!xiii) ''Principle Trunk Infrastructure' shaii mean the trunk infrastructure such as road, street
lighting, drainage, sewerage, water, etc. to/at the Reschedu ed licensed Land;
(!xiv) "Project" shalf mean and include development of the following on tt,e Collaboration Lano
as part of the Project, in terms of this Agreement:
Residential group housing by consuming FSI-Col\2boration Land and Density

Collaboration Land;
Community center/dub house for use by tt1e oo:;cupants of the res1clential

development on the Collaboration Land, as may be :::onceptualized by HMRPL:
Car park1n(;'i spaces that are constructed in accordan::;e with the conceptualization
of the Project-, to a minimum of what is required urder Applicable Law/ Zornng
Plan:
Other amenities and rac1hties appurtenant to and pern,issible to be developeo :is

under /\pp!icabte !-a\"-/t such as ~ennis couris
svvirnminsi open areas I garden spaces etc , as may be conceptualized
HMRPL.
{e) Col!abcra:ion LancH:WS Units
(f) Infrastructure development specific to the Collaboration U:ind;
ORNAMENTAL BTVS BUILOWEIJ._ ADSON SOFTWARE BASE l:XPOfffS HERITAGE: MAX

REALTORS PRIVATE UM!TED PRIVATE UMITED PRIVATE LIMITED REALTECH
PRIVATE PRIVi\TF
LIMITED LtMITED
GOLDEN HI ENER.GY BUI LS REALTORS COMMANDER IREO PRIVATF

VIEW REAL TORS Pf\lVATE PRIVATE LIMITED REALTORS PRIVATF
BUILDERS LIMITE:D UM!TE:D
PR!W,TE:
UMlTFD
21
&
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(g) Any other development in accordance with Beneficial Interest Perm:ssion and/01
,t\pprovais.
(lxv) "Project Facilities" shall have the meaning as ascribed to such tt"mn under Clause 8.G
Gf !his /\greement
(lxvi) ·saleable Area" or "Saleable BUA" shall mean and rndude tho carpet area (wa!Ho
1;vall), area under the walls/ wall clodding, proportionate share of area to be utilized for
common use ,3nd faciM1es, such as terraces, lobbies, atriurns, AHU rooms, shafts.
passages, corridors. refuge area. stilts, common amenities and services like electric sub•
station, stand-by generator, fire-fighting equipment, building mana9ement systems, \.vater
tanks, washrooms, shafts, machine rooms, staircase, !ift wells, security booths, common
rooms, common Gorridors, hefipad, clubhouse with pool, entrance porches, pump room,
STP, maintenance stores and offices, driver's toilets and open spaces and the like or any
other service area used for common services etc., as may be calculated for all
apartments/ units in the entire Collaboration Land, which calcuia!ions shall be made by
HMRPL;
(!xvii) "Total Project" shall mean and refer to the development of group housin9 colonies and
all other appurtenant facilities, amenities and infrastructure required/ permitted to be
developed on the Rescheduled Ucensed Land under the License and Applicable Law
and as per the norms set out in the Combined Zoning Plan;
()xviii) 'Total Project FS!" shall mean the total FSI presently avaiiable for t11e Reschedu,eo
Licensed Land, which rs 2,443,133 square feet as represented by IREO;
(lxix) "Zoning Plan'' shall mean and refer to the combined zoning plan currently sanctioned by
DTCP in respect of the Licensed lands.
12 Interpretation
1.21 In this Agreement, unless the contrary intention appears any reference to ary statute or statutory
provision shall inc!u<:.1e
i\
( i/ all subordinate legislation made from time to time under that statue or statutory prov,s1on
(whether or not amended, modified, re-enacted or consoidated);
ORNAMENT;'.\L BTVS BU!U)WELL ADSON SOFlWARE BASE E:XPORTS
REAL TORS PR!V/\TE LIMITED P!~IVATE UM!TED PRIVATE LIMITED
PRIVATE
LIMITED
GOLDEN HI ENERGY BULLS RE1\LTORS COMMANDER

V\E\/V REALTORS PF~!VATE PRIVATE UM!TED REALTORS PRIVATE
BUILDERS UMITED LIMITED
PRIVATE
LIMITED
22 if'
&
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(ii) such provision as from time to time amended, modified, re-enacted or consolidated
(whether before or after the date of this Agreement) to the extent such amendment,
rnodificalion, re-enactment or consolidation applies or is capable of applying to any
transactions entered into under this Agreement and (to the extent liGbility thereunder may
exist or can arise) shall inc!ude any past statutory prcv,sion (as fron1 tin1e to time
amended, modified, re-enacted or consolidated) which tre provision refem;d to has
directly or indirectly replaced;
any reference to the singular shall include the plural and vice-versa:
(iv) any references to the masculine, the feminine and the neutE,:r shall include eacti ouier;
(v) any references to a ''company" shall include a reference to a body corporate:
(vi) any reference herein to any Clause or Schedule or Annexure is to such Clause of or
Schedule to or Annexure to this Agreement. The Schedules and AnnE:xures to this
Agreement shall form an integral part of this Agreement;
(vii) references to this Agreement or any other document shall te construed as reference:;; to
this Agreement or that other document as amended, varied, nov,,,ted, supplernented or
replaced from time to time:
(viii) the expression "this Clause" shall, unless followed by refe ence to a specific p,o,1,s1on,
0
be deemecl to refer to the entire section (not merely the su') se,:;tion, parn::;raph or other
provision) in which the expression occurs;
each of the representations c)nd 'Narranties provided in this Agreement is of

other representations and warranties and unless the contrary expressly siated no
c:.ia1.;se in this ,t\greernen1 n0~its the extent or application cf aroth8r (~lnuse ?n\,1 03rt
thereof:
(x) any reference to books, tiles, records or other information ;:;r any of them rnei,ViS book~,
files, records or other information or any of them in any forn or in •Nhatever medium he lei
nc\uding paper, electronically stored data, magnetic media, film and microfiirn
(xi) headings to Clauses, parts and paragraphs of Scheou!es and Schedules are fer
OF~NAMENTAI 8T✓S BU IL.DWELL A0SON SOFTVVARE BASE EXPOFffS HFf~iTACE M/\J:
FZEALTOF\S PRIVATE LIMITED PRIVATE llM!TE0 PRIVA-T: UMl iED hl::i\LT EU!
PRIVATE PFZlVAfE
UMITED LIMiTFTJ
GOLDEN Hl ENERGY BULLS REALTORS COMM.A,NDH~

VIEVV REALTORS PRIVATE PHlVATE UM!TED REAl-TCRS PPl\//,TE
BUILDERS LIMITED UMITl::D
PRIVATE
!. li\ti!TED :~\ ,·':•-_/
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307
convenience oniy and do not affect the interpretation of this Agreement;
(xii) "in writing" includes any communication made by letter, fax or e,mait;
{xiii) the words "include", "including" and "in particular" shall be c,Jnstrued as being by way of
illustration or emphasis on!y and shall not be construed as, nor shall they take effect as,
limiting the generality of any preceding words;
(xiv) references to a person (or to a word importing a person) shall be construed so as to

include:
(a) individual, fi,m, partnership, trust, joint venture, company, corporation, t)ody
corporate, unincorporated body, association, organization, any gQvernment, or
state or any agency of a government or state, or any iocal or municipal authority
or other govemmeniaf body (whether or not in each case having separate legal
personality);
{b) references to a person's representatives shaH be tc i\s officers, employees. legal

or other professional advisers, sub-contractors, ag,mts, attorneys .and other duly
authorized representatives;
(xv) where a wider construction is possible, the words "other" and ''otherwisQ' shall not be
construed ejusdem generis witf1 any foregoing words;
(xvii all the recitals to this Agreement shall form an integral and operative part of this
Agreement as if the same were set out and incorporated verbatim in the operative part
and to be interpreted, construed and read accordingly.
2. DEVELOPMENT OF PROJECT
2.1 On and from the Effective Date, !REO and the Land Owners hereby grant in favor of HMRf:::iL
rights and interests of IREO over the Collaboration Land / the Project in terms of the L.anu
Owners-tREO Development Agreements to enable HMRPL to develop the Project on the
Co!laboration land in the manner and on the terms and conditions cont:alned in this /\greement.
Accordingly, pursuant to the rights granted hereunder, on and from the Effective Date, lf~EO anc!
HMF~PL shall respective!y carry out fREO Obligations ancl HMRPL Obiir;ations in the manner as
ORNAMENTAL BTVS BUILOWELL ADSON SOFTWARE BASE EXPORTS HFRiTACF M/o.X
REALTORS PRIVATE UMlTED PRIVATE UMlTED PRIVt,Tf: UM!TED f:;;E/\LTFCH
PR!VATF PR\V/\f[
UMITED UMITED
GOLDEN HI ENERGY BULLS REALTORS COMMf\ND EF~

V!EVV REALTORS PRIVATE PRIVATE LIMITED REM.. TOf-!S PHJVATE
13U!LDERS UM!TED I lMffED
PRIW\TE
UMlTED
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provided in this Agreement
2.2 The Project shall be developed by HMRPL and IREO undertaking t7eir respective, separate and
specific obligations in the Project/Collaboration Land, in the manner set out in this Agreement
2. 3 The Project on the Collaboration Land shall be developed by HMRFL and IREO by implementinrJ
the HMRPL Rights and HMRPL Obligations and !REO Rights nnd lF{EO Ob!inat1ons respectively
2.4 HMRPL shall have the absolute and uninterrupted rights and be fully entitled to implement and
utilise the HMRPL Rights and IREO shall be entitled to implement and utilise the !REO Rights
in accordance with the terms of this Agreement.
. 2.5 HMRPL has the irrevocable rights and is fully authorised tc enter upon the Collaboration Land
directly or through 1ts Affiliates, associates, norninees, agents, ar..::hitects, consultants,
representatives, contractors, and/ or subsidiary, to do all such acts and deecJs required and/or
necessary for, exercising the HMRPL Rights and/or HMRPL. Obligations ior the implementation
of the development of the Collaboration Land.
2.6 HMRPL shall have the right to utilize, construct and develop 1,000,000 (One Million) square feet
of thi) FS! and 8.917 acres of demarcated land ie the Coltaboration FAR on the Collaboration
Land and utilize the Density-Collaboration Land on the Collaboration Land out of the Total Pro1ect
FS! and Density~Ucensed Land as part of the Project IREO and HMRPL will undertake the
development of the Collaboration Land in accordance with HMRPL Right,t HMRPL Obligations,
IREO Rights and IREO Obligations respectively and all other terms contained in this Agreement
'Wherever required under the Approvals and the Applicable Laws, !REO :;h~111 be responsible to
obtain the Customer NOCs, at its own cost to enable HMRPL to freely exercise the HMRF'L
Rights. HMRPL shall provide reasonable assistance to lREO in this regard
2. 7 lt 1s agreed and undf,rstood between the Parties that HMRPL ha::: enter1"d into this Agreernem
on tre representation of !REO that the FS!-Co!!abor::;itinn Land is perrnittod to be clevelooed on
the Collaboration Land, and the same shall be utilised as part of tre Project In the event of any
reduction in the FSI available to the Rescheduled Ucensed Land / Col!aboratior Land / IREO
Principle Land, the FSI- lREO Principle Land would reduce, without any impact on the FSI-
Collaboration Land that is to be utilised on the Collaboration Land.
28 Notwithstanding anything to the contrary contained 1n this Agreernen:, is specifically agreed

between the Parties that in ~he event any increase in r:s1 is available/permissible on the
OF~NAMENTi\L BTVS BUH.DWELL 1\DSON SOFTWARE BA.SE C::XPOF1 rs HE:R!T/\GE: MAX
REALTOFIS PRIVATE UMlTED PRIVATE LIMITED PRIVATE UMITED REALTFCH
PRIVATE PRIVATE
UMITED LIMITED
GOLDEN HI ENERGY BULLS RE1\LTORS COM\'1ANDI n

VIEW REALTORS PRIVATE PF~IVATE LIMITED R.E:ALTORS PRi'/AT[
PRJ\/ATE
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Rescheduled Licensed Land, IREO shall be entitled to such increased FSI upto 2.J5 (34,98,35B
sq. ft.) and the corresponding increase in density if any. It being clarified tht1t lf~EO will be entitled
to such increased FSI fess the Collaboration FAR (ie. 34,98,358 less 1,000,000 sq. ft) and s!,a!1
be entitfed to consume the same on the IREO Principle Land or any other land (except
Collaboration Land) or, subject to the aforesaid, to deal with it in any manner it may deem fit In
case of any alteration of the FSI- IREO Principle Land and Density - lREO Principle Land as
provided in this clause, IREO shall duly inform HMRPL of such alteration within 7 (seven) days
Provided always any increase of FSl over and above 2.35 (34,98,358 sq ft.) with respect to the
Rescheduled Licensed Land and the corresponding lncrease in cens1ty if any sha!! be shareo
between the Parties in the ratio of FS! available with the Parties as of today (i.e. 40 93% to
HMRPL and remaining to lREO and for it's nominees). Such inc~ease 1n FSI over and above
2.35 (34,98,358 sq ft) shall be proportionately divided between t'1e Pro[ed- and !REO Pro1ect
in the proportion as if!ustrated below i.e:
in the same proportion as the current FSI on the f~escheduled Licensed Lands 1s bemg
divided between the Collaboration Land and the Hernaininu Rescheduled Licensed Land
(such proportionate increase in FSI on the Col!aboration Land IS )1ereinafter caiied
"Additional Collaboration FAR''}:
(b) Increase in density shall be divided in the same proportion as the cur~ent density or• tr:r,
Rescheduled Ucensed Lands is being divided betw,~cn the Coll::i.boration Land and ir1e
Remaining Rescheduled Ucensed Land.
In this regard it has been clarified that
Cost and expenses (including additional EDC/lDC) en account of the Additionai

Collaboration FAR, shaH be to the sole and exclusive account of HMRPL
() HMRPL is free to avaH additional density provided by tt·1e authorit1et; that may be avaiiab!e
with the Additional Collaboration FAR in accordance with this cliwse
HMRPL can use the Additional CoHabotation FAh: as per its sole ciiscretion in accordance
with the Applicable Law. HMRPL shall have entire Development Hights over ttie
ORNAMENTAL BTI/S BUlLD\NELL -4.DSON SOFTWAF.,>F BASE E::<P<.mTS HERITAGE MAX

REALTORS PRIVATE LIMITED PH!V,l\TE UMITE.D PRIVATE! IMiTED IC:.:EALTECH
PRIVATC PRiVPJ!:::
LIMITED LIMITFD
GOLDEN HI ENERGY BULLS f~EALTORS COMMANDER

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BUILDERS UM!TED UMITF:D
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Add,!ional Collaboration FAR and HMRPL shall be entitled t:; deal with the same as per
its sole discretion in accordance with tho Applicable Law
u HMRPL s~1all be entitled to appropriate the entire amount of sales proceEds, including
EDC and IDC etc. as may be levied / passed onto the customer rel;:;ting to the Addit1on:::ii
Collaboration FAR
o Land Owners, lREO and their nominees will execute/have executed powe,, of attorney/
documents required for granting powers to HMRPL or its norninee for exerciging the rights
aver the Additional Collaboratlon FAR. However, aH ccsts towards stamping anci
registration of such agreements shall be borne by HMRPL
o Wherever any Customer NOC's are required under the Approvals and the Applicable
Laws, IREO shall be responsible to obtain such Customer NOCs, at the cos! and c,xpense
of IREO, HMRPL st1a!I provide reasonable assistance to IREO in this regard.
It is however clarified herein that in the event !REO avails of any advantage of the Additional
FAR, aH and any cost/expenses in relation to the same shall be tM sole liability of IREO only
wit11out any such !rability accruing on HMRPL
Provided always in the event any area which is currently free of FP.R is included ;,1s part of FAF~
and Government increases the FAR (with or without corresponding increase in density) to
compensate such change, HMRPL shall be entitled to the increased FAR (with proportionate
increase in density if any) proporiionately. All such proportionate costs and expenses thereof
shall be to HMRPL's account It being clmified that HMRPL shall be sntitled to only that increased
FSI which 1s permitted by the Govemrnent to compensate such change. In case of such change
in policy and provided that HMRPL is {:ntitled to such increased FSI, then the entitlement of \Rf()
relating to 2.35 FAR as per this Clause shall be proportionately increased
2.8 r'!~v1RPL shaH have no ,'.:J'>/er any ~;f the f-'.eschedu!ed Ltcensed Land or the t ir.ensed
FAR or the Additional F.AJ~ (as defined later) other than on :he Collaborat:on Land, the
Collaboration FAR and the Additional Collaboration FAR Provided that, IHEO I Land Owners or
their nominees / assignees ! transferees shall not undertake any act, deed or thing which may
adversely affect the rights sought to be vested in favour of the HMRPL with ,·espect to the
Callaborat1on Land.
ORNAMENT;:,:_ 8T\/S BUtLDWEU ADSON SOFTWARF BASE i=XPORTS HERITAGE Mf\X

REALTOF~S PRIVATE UM/TED PRIVATE LIMITED PRIVATE LIMITED REALTECH
PRIVATE PR!V;\H;
UMITED LIMITED
GOLDEN Hl ENERGY BULLS RE.!1LTORS corvlMANm:R

VIEW REALTORS PRi\f.1\TE PPIVA IF LIMITED RE.i'.\LTORS PRIVATE
BUILDEf~S LIMITED LIMITED
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The area marked 1n grey coiour measuring 0 28 acres in the plan annexed as Annexure !I which
depicts the same upon the obtainment of the re-schedulernent of the Licensed Land will bo a
public road and form access to the School Lands and also an additional access to the
Collaboration Land as per the Government approvals. lREO hereby represents and assures to
HMRPL that such optional access to the Collaboration Land shall always be kept free from a!I
obstacles and shall never be blocked, shifted or removed which shall cause any hindrances for
the purposes of ingress eqress to the Collaboration Land. AH documents, applications, p!ans etc
to be filed by iREO with the authorities for obtainment of Combined Zoning sha!!, before filing
thereof. be provided by if~E:O to HMRPL for its review. To ensure that subsequent to the
obtainment of the Combined Zoning for the Resche<ju!ed licensed Land, the Collaboration Land
is of the description, shape and size as the land shown in Annexure ll hereof.
!REO and \ts nominees atone shall be entitled to the IREO Principle Land i.e the balance lard
admeasuring 25.258 acres cf the Rescheduied Licensed Land (Le. Rescheduled Licensed Land
less the Collaboration Land, but including Land under Roads and School Lands) with the right to
utilb:e and develop the remaming FSl available on the Rescheduled Licensed land to the extent
of FSHREO Princip!e Land, as per current regulation. Subject to and in accordance with 2.8
above, any amendment in the prevalent !aws resulting in increase of FSf over the Rescheduled
Licensed Land (such incn:;ased FSJ calied the "Additional FAR") shall be consumed by !REO
on the IREO Principle Land or any other !and parcel (other than CoHaboration Land) at its own
cosl and expenses, and be to the sole and exclusive account of IREO/nom1nees of IREO. The
Collaboration FAR and !REO Principle FAR aggregating to 2,443.133 sq ft is referred to as the
"Rescheduled Licensed Land FAR".
210 !REO is already developing the lF<EO Another Collaboration land in accordance with the !HEO
Another Collaboration Umd FAR. !REO Another Collaboration Land is markecl in brown crnour
in the plan annexed hereto Annexure I! which depicts the IREO Another Collaboration Land upon
the obtainment of the r;;;~schedulement of the Licensed Land, For securing the approvals for
!REO Principle Land. HMRPL shall not be obliged or bound to change or modify its
i~fr•,.: dtd!!r"lri r.,., ,,...,+h.-:-;-.~
\•')ltl"\t
H:..,..'f\.JU~J
lsJv!ls\.,!1< • ~ VI -.,-~, ,,,,_,, of Pro.lcct any rnanner.
2.11 fa,s per the sole discretion ot HMRPL, Density utilized on Co!!aboration Land shall be up to 3,562
number of persons on the Collaborotion Land or such higher dEnsity under Clause 2.8 herein
2.12 The commercial areB entitlement on the Collaboration Land shall be at least 2,857 sq. ft., out of
the Collaboration FAR and the balance 997,143 sq. ft. shall be fer residential use, including EWS
and community center/club (relating to the Collaboration Land}.
ORNAMENTAL BTVf, 13UILDlfvFl.. L ADSON SOFTWARE BASE EXPORTS HERITAGE M,A.X
REALTORS PRtVATE UMlH:D PRIVATE UMITED rJRJVATE LIMITED REA.LTECH
PRlVATE PRIVATE
LIMITED LIMITED
GOLDEN HI ENERGY BULLS REALTORS COMMANDER !REO PRIVATE

VlEVV HEAL TORS PRIVATE PRIV/>TE LIMITED REALTORS PRIVATE:.
BUlLDERS UMITFD L!MITED
PRIVATE
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2.13 EWS housing relating to Collaboration land (i.e proportionately attributable to tb3 primary
dwelfing units to be developed on the Collaboration Land) shall be constructed by HMRPL on
Collaboration Land
2 14 EWS housing relating to IREO Pn1;c1ple Land (i.e. proportionately attributable to the pnrnary
dwelling units to be developed on the IREO Principle Land or any other land (except
Collaboration Land) as may be permissible under Applicable Laws) shall be cons'.:ructed on the
IREO Principle Land or such any other land (except Collaboration _and) as may be permissible
under Applicable Laws) by IREO or its nominees. IREO and/or its nominees shall ensure that
the same are duly built as per the Combined Zoning I specified CTCP requirements such that
the OC for the units or part thereof, as the case may be, to be buils: over tr1e Collaboration Umd
is neither delayed nor withheld and that the same is built simultaneously with the other
construction development on the Collaboration Land and IREO Prirciple Land ( or any such other
tanct (except Collaboration Land) as may be permissible under Applicable Laws) to be
undertaken by HMRPL and !REO respectively. Upon sanctionhg of the building plans for
Collaboration Land, HMRPL and !REO shall intimate to each other tt1e time!ines fer completion
of EWS housing units on the Collaboration Land and IREO Principle land (or any suer, other
land (except Collaboration land) as may be permissible under Applicable Laws) respectively. In
the event IREO is unable to construct and develop the EWS units on the IREO Principle Land
(or any such other land (except Collaboration Land) as may be .oermissible under Appiicable
LavJs) within the timelines as may be agreed, HMRPL shall have the :igh• but not the cbiigation
to have them developed and constructed at the cost and expense:, of iREO.
2. 15 HMHPL. st,all ensure that EVI/S housing relating to Collaboration Lane is duly built in proportion
to the number of units built thereon from time to time as per the CoHaboration FAR and Combined
Zoning/specified DTCP requirements and such that such that the OC for the units or part thereof
as the case may l)e, to be built over the Collaboration Land is ,either delayecl nor w1tt1helcL
HMRPL alone shalt be entitled to all sale proceeds from the sa!e of the EWS housing units
:-eiGting to H,e C::itlabcration Lard. In the event HMRPL is unable to construct 2nd clevelor. the
E\iVS units on the Collaboration Land within the timelines as may be agreed. IREO shall have
the right but not the obligation to have them developed and constn.:cted at the cosi and exponses
of HMRPL
2. ·1 G The Parties recognize and accept that (a) certain services may be but not necessarii\' ::airnnoP
to and shared between the Collaboration Land and the lREO Principle Land ar:d Geria1r,
pipelines, water storage tank(s), HT substation, cables, sewers, r2in water pipes. etc. may serve
OHN/\MENTAL BTVS BU!LDWEU.. ADSON SOFTWARE BASE EXPorns HEF:lTAGE MAX
f~EALTORS PRIVATE LIMITED PRIVATE UM\TEO PRIVATE ;1MITFD HEAL TECH
PRIVATE PR!VATE
LIMITED IM!TED
GOLDEN Ht ENERGY BULLS REALTORS COMtvt,\NDER

VIE\/1,1' REALTORS PRIVATE PRIVATE UMtTED REALTORS PRIVATE
GUILDERS LIMITED LIMffED
PRtVATE
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both Collaboration Land and the !REO Principle Land {hereinafter coi!ective!y referred io as the
"Rescheduled Licensed Land Facilities"). The Resct,eduled Licensed Land Facilities may run
across/under either Collaboration Land or the !REO Principle Land, IREO Another Collaboration
Land or across/under ali, within efficiently located and defined service corridors. Upon rnutual
discussions and understanding betiveen !REC and HMRPL and no fater than 9 (nine) months
from the Effective Date hereof, such service corridors shall be dearly defined and mutually
agreed and it shalt oo the soie responsibility of IREO to implement s<1ch understanding in relation
to the service corridors and facilitating access of the Rescheduled LicBnsed Land Facilities
/Collaboration Land Facilities (as defined below) through such ~,ervice corridors within such
Ume!ines as may be agreed betvveen IREO and HMRPL and the same may run across/under
either Collaboration Land or the IREO Principle Land, IREO Another Collaborat1on Land or
across/under al! of them. The Rescheduled Licensed Land Facilities to the extent whether it falls
within the Collaboration Land or the lREO Principle Land shall be c1eveloped by !FtEO at its own
cost anc!w\thin agreed timelines so as to facilitate expedit[ous deveiopment and hG1ndover to end
users of Collaboration FAR Prior to implementation, HMRPL and lREO will mu-:ual!y discuss.
coordinate and finalize the plans. Notwithstanding anything contained in this Agreement, it shall
be the sole responsibility and liability of IREO to deal with and obtain NOCs, if any required, frorn
Mahindra Homes Private Limited at its own cost in order to fulfil! me IREO Obligations and free
exercise of HMRPL R\ghts by HMRPL; lREO and HMRPL will cooperate with each other to
ensure that the Rescheduled Ucensed Land Facilities whetherfalling within !REO Principle Land
or th,3 Collaboration Land respectively, runs most efficiently, in a planned manner and with ieast
disturbance to the development on either of such !ands. !REO agrees to provide tapping points
forthe Collaboration Land Facilities (as defined tater) at the periphery of the Collaboration l-and
as may be requlred for development over the Collaboration Land IREO shaH ensure that the
Reschedu[ed Licensed Land Facilities to the extent undertaken by it and which may run
across/under either Collaboration Land or the IREO Principle Land, IREO Another Col!aborat1on
Land or across/under aH of them is completed within such time period as rnay be mutuaily agreed,
but in any event, prior to the application for Occupation Certificate or part Occupation Certificate
("OC") to be made to the DTCP for the units or part thereof, as the case may be, to be deve!opcd
over the CoH2bonation Land such that the OC for the units or part thereof, as the case may be.
\o be developed over the Collaboration Land is neither delayed nor withheld.
It is provided fo1 the sake of clarity that the 12m wide service road adjacent to the Co laborat101,
Land shall be developed by HUDA or IREO as the case may be
In relation to the Collaboration Land it has been agreed between :he Parties that m the event as
per the requirement of concerned authority, the development of the Rescheduled Ucensecl Lancl
ORN/\MENT.1\L SNS BUlLDWELL t~DSON SOFTWARE BASE EXPOfUS HERiTAGE Mf....X.
1~E/\LTORS PRIVATE LIMITED PRIVATE UM!TED PRIVATE LIMITED REALTECH
PRIVAH: PF/IVAT L
LIMITED UMiTED
GOLDEN HI ENERGY BULLS REAL TORS COMMANDER lnE() PF:lVA TE

VIEW REALTORS PRIVATE PRIVATE UMITED REALTORS Pf~IVATE l.
BUH.DERS UM!TEO UMITED
PFWATE
UM!TED
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Facilities encompasses the installation of only one electrical sub-station then IREO shall provide
land for the same without any cost
2.17 Except to the extent of any Rescheduled Licensed Land Facilities to be developed by IREO
across/under the Col!aboration Land, the Project to be developed on the Collaboration land shall
be distinct and separate from the project(s} to be developed on the 1REO Principle Land
2, i8 The entire Rescheduled Licensed Land FBcilities which is/are exclusive for the Project on the
Collaboration Land ("Co!laboration Land Facilities') shaft be developed by IREO in
consultation with Hl'v1RPL at !REO's own cost and expenses. It is agreed that in the event an·,
component of the Rescheduled Ucensed Land Facilities is approved separately for the
Collaboration Land by the Government Authorities then the same shat! also be developed by
IREO at its own cost. IREO shall complete the Collaboration land Facilities within suet,
timeframe as may be mutually agreed between the Parties.
2, 19 The CoHaboration Land Facilities shalr be exclusive for the apartment owners on the
Collaboration Land, without any entitlement of I sharing with the apartment owners on the IREO
Principle Land, and similarly the trunk infrastructure on the IRED Pnnciple Land shall be
exclusive for the apartment owners on the iREO Principle Land.
2,20 The School(s) as required to be developed in accordance with the requirement of the License
wm be developed by !REO or its nominees on the SchCJol land at its/their ov.m cost and expense.
[f such School(s) are required to be developed prior to grant of OC by DTCP for the units or part
thereof, as the case may be, to be developed over the Collaboratio, Land, tREO or its nominees
wii1 build the same within such tlmelines that OC for the units or part thereof to be developed
over the Collaboration Land is neither delayed or withheld. lREO or its n<Jminces alone shall be
entitled to deal witi1 the said School(s) and al! consideration/incomes tnereof in compliance with
the Applicable Laws, ln the event of failure by lREO to build thE, Schoni(s) 'Nithin the agreed
timeHnes, HMRPL shall have the right but not the obligation to have the same constructed and
developed at the risk and cost of !REO Tris right of HMRPL shall however be without prejudice
to its right to have itself indemnified by IRE() under the terms of Claus<:: \0 of this Agreement.
2,21 !REO will execute and cause the Land Owners to exer.:ute and register necessary power of
attorney / documents required for granting powers to HMRPL or its norn\nee for exercising the
rights over the Collaboration Land as set out herein and effocting aHotment, transfer and
conveyance of each unit comprised in the Project to be developed over the Collaboration Land
and to execute and register the documents on behalf of IREO and Land Owners tor sale i
ORNAMENTAL BTVS BUILDWELL ADSON SOFTWAl~E BASE EXPORlS HERITAGE MAX
REALTORS PRlVATE LIMiTED PRIVATE LIMITED PRI\J,t,TE LIMITED REALTECH
PRIVATE PRJVATF
UMITED LIM!TFD
GOLOt:N Hi ENERGY BULLS RE.AL TORS COMMANDER IREO PRIVATE

VIEW f~EALTORS PRIVATE PRNATF UMITEO REALTORS PRIVATE
BU!LDEF:;S LIMITED UMITED
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conveyance of the Saleable BuA, EWS and the commercial areas I spaces, and the Lane!
Owners of the Collaboration Land undertake to do the same. However, all cnsts towards
stamping and registration of such sale / conveyance deeds shall be borne by the al!ottees i
buyers.
3, IMPLEMENTATION OF THE PROJECT
3.1 !REO undertakes full responsibility and obligations to comply with tREO Obligations and incur ail
IREO Costs.
3.2 Notwithstanding the IREO Rights, the landscaping, conceptualization, planning, architecture.
construction and design of the entire Project shall be at the solEt d1scmtion and expertise of
HMRPL, without any recourse to or interference from lREO and I or the Lsnd Owners Tne
detailing, master planning, zoning, lay out, etc. and al! other details and spi3cification for
devEdopment of the entire Project on the Collaboration Land shall also be done by HMRPL.
3.3 HMRPL shall be entitled to appoint employ or engage architects, surveyors. engmeers.
contractors, sub-contractors, labour, workmen, personnel (skilled and unskilled) or other persons
to carry out the development work forming part of HMRPL Ri9hts and to pay the wages.
remuneration and salary of such persons.
34 HMRPL. unclertakes full responsibility and obiig,,tiom; to comply with HMl<PL F"\ifJh::s anc.l Hr\,1RPL
Obligations in timely manner and incur all HMRPL's Costs. Further, it is clearly agreed ancl
understood that towards compliance of HMRPL Rights :md HMRPL Obligations, and to ensure
harmonious development of the Project, HMF~PL sr·aH only employ reputed ccntractcrs.
architects, surveyors and engineers, and enter into contracts with them. as is standard industrv
practice.
3.5 It is clearly agreed and understood that towards compliance of !REO Obligations and to ensure
harmonious development of the ProjRct lREO shaH only empioy construction contractors,
architects, surveyors, consultants, technicians, engineers and all other service providers out of
a list of such contractors, architects, surveyors. consultants, engin,:;ers and servic1? providers that
stialt be approved by HMRPL for the development of the Coilaboration land H, accordance witl'.
the terms of this Agreement or that n,ay be suggested HMRF'L to IREO Further, tu ensure
harmonious and smooth development of the Project the contracts/ agremnerts l arrangernems,
',Nork orders and instructions that are entered with / issued tc such cortractors, architects.
surveyors and engineers by lREO from time to tirne shall require to lx, approved by HMf~PL.
ORNAMENT,i\L BTVS BU!LDWELL ADSON SOFTVVARF DASE E:XC:>oFns HERIT AGf MAX
RE.AL TORS PRIVATE UMiTED PRIVATE LIMITED PRIWiTE UMiTED REALTECH
PRIVATF PRIV/lff
UM!TEO LIMrHTl
.... A.
GOLDEN HI ENERGY BULLS REAL TORS C0 1v1M/,NDER !REO f'R!Vfa, re

VIEW REALTORS PRIVATE PRIVATE UMITED F~EALTORS PR!VATE
BUILDERS LIMITED LlMiTED
PRIVATE
UMl"fED
J2 ! '
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HMRPL shall be entitled to suggest modifications/changes to the contracts/work orders 1n

consonance with the landscaping, conceptualization, planning, arcriitecture, construction and
design of the entlre Project prepared in accordance with Clause 3.2 above and as may be revised
from time to time by HMRPL !REO further undertakes to employ contractors, architects.
surveyors, consultants, technicians, engineers and all other service providers for the !REO"
Collaboration Land Development Obligations.
3.6 HMRPL shali be entitled at its sole discretion ;o appoint I nominat,} any of its Affiliates or ;:my
other entity as a development project manager I development manager to undertake the
development and construction of the Project and all obligations, rights and entitlements of
HMRPL under this Agreement and to transfer I assign all such enlit!ements and obligations in
favor of the said Affi!iate or any other entity as may be deemed appropriate by HMRPL Ne
approval or consent shaH be required in this regard from !RE:O and for the Land Owners.
3.7 Approvals
3.7.i Zoning Plan Approval: The Zoning Plan for the Rescheduled Licensed Land is uncler process of
approval and shall be accordingly obtained by IREO
3,72 HMRPL shaH, subject to force rnajeure, file the building pian relatinq to the ProJect/Collaboration
Land for sanction with DTCP within 9 (nine) months from the later of Closing Date-3 and the date
of receipt of Change in Beneficial Interest Permission.
3.8 IREO and Land Owners shal! extend all cooperation and do all such acts and deeds, that may
be required to give effect to the provisions of this Agreement, including, providing all such
assistance to HMRPL, as may be required by HMRPL from time to time for the purpose of
carrying out the transactions contemplated hereby. lREO and land Owners fLirther agree to, and
shall execute, as mav be required by HMRPL 01" otherwise, from time to time. all applications
affidavits, plans or other documents, and shal: also extend all cooperatim: and assistance for the
deve\opmer:t and cornpleF0° of tre Projpct 2nd marketing / allotment I sale / transfer of tnc:
HMRPL's BUA IREO shall furnish at! such relevant information in respect of the Collaborat1on
Land, as HMRPL may request for ti,e purpose of carrying out the transactions contemplated
hereby. In the event HMHPL requires any assistance inc!udin£/ execution of any document
application, affidavit pow,::,r of attorneys. etc, IREO shall do so, subject to compliance of !eqa!
requirements thereof. within 7 (seven) days ot receiving the request from HMFPL
ORNAMENTAL BTVS BUH.DWFU. ADSON SOFTWARE BASE EXPORTS HEl~ITAGE MAX

REALTORS PRIVATE UM\TEQ PR!\/ATE LIMITED PR!Vt\TE LIMITED REALTECH
PRIVATE PRIVATE
LIMITED
GOLDEN HI ENE:f=<GY BULLS REALTORS COMMANDER

VIEW REALTORS PRIVATE PRlVATE LIMITED REAL TORS PRIVATE
BUILDERS LlM!TED LIMITED
PRIVATE
UMITED
&
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317
3.9 HMRPL shall extend ali cooperation and do al! such acts and deeds, as may be required by
lREO from time to time for the purpose of cam;ing out the development in relation to the !REO
Obligations, within reasonable time of receiving request from !REC.
3.10 Without preiudice to the obligations and entitlements of lREO, the Land Owners, sha\l do ::iii
deeds, acts and things as are required for lo be done by them in accordance with this Agreement.
tREO and the Land Owners agree and undertake, to execute irrevocabh,, power of attorneys in
formats which are duly agreed, in favour of HMRPL or its representative in respect of the entire
Collaboration Land, so as lo enable HMRPL to perform HMRPL Obligations and exercise
HMRPL Rights under this Agreement (all Power of Attorneys are col.!ective!y reforred to as the
"HMRPL GPA') !REO and the Land Owners are fully aware that HMRPL has entered into this
Agreement relying upon their representations that the HMRPL GPA shalt be maintained and not
revoked. 1REO and the Land Owners fully understand and agree that in the absence of the
HMRPL GPA, HMRPL shaH not be able to perform HMRPL's entitlement to implement its
obligations relating to the Pro1ect and to market and seH the HMRPL's BUA Thus IREO and the
Land Owners agree and undertake not to car.eel, revok.e or modify the HMRPL GP/I, and to keep
the same in full force and effect as may be required for HMRPL to undertake and complete all
HMRPL Obligations and HMRPL Rights. The HMRPL GPA shaH be irrevocable and HMRPL
shaH be entitled to delegate any or all of the powers and authorities under the HMRPL GPA to
any of its Affiliates, employees or representatives" HMRPL shaH have an unequivocal right of
specific performance in the event of revocation I modification I alteration or cancellation of the
HMRPL GPA, prejL,didal to HMRPL or otherv1ise along with all injunctive remedies. HMRPL GPA
shall be executed and registered, at the cost and expense of HMRPL simultaneously with the
execution and registration of this Agreement.
3, 11 It being expressly agreed that 1n the event IREO fails to take effective steps with respect to ;.my
of the !REO Obligations, induding with regard to obtaining the Approvals and/ or any renewal/
extension in respect of the same as well as renewal/ extension of License, then notwithstanding
any other right or remedy available under this Agreement or Applicable Law, HMRPL shall be
entitled to take nec"2ssa,y steps for obtain\ng such Approvals under tr1e authotisation granted
vide HMRPL GPA at lREO's cost It is however aoreed between the P,arties that !REO sl,all be
obligated to appfy for the ronewal of License and ;bligated to obtain the Combined Zoning.
3. 12 To facilitate/carry out the construction and development of the Project on the Cotlaboration Land
and/or for discharging any HMRPL Obligations, HMRPL shall have the right to create equitable
mortgage (by depositin9 and/or actual and/or by way of constructive delivery, the original title
deeds and documents) er registered mortgage or any other form of mortgage or securitization or
ORNAMENTAi BTVS BUIUJWEU.. ADSON srn:Tw,,\RE BASE EXPORTS HERlTAGE Mr'\,:<
REAL TORS PR1VATE l. IMITFD PRIVATE UMITEO PRNI\TE LIMITED REALTECH
PRIVATE PRIVATE
UMITEO LIMITED
~
jJ/ ' \
GOLDEN HIENERCY BULLS REAL TORS COMMANDER

VfEW F:EALTORS PRIVATE PRIVATE LIMITED REALTORS PRlVATE
BUILDERS LIMlTH) LIMITED
PRIVATE
LIMITED
&
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318
exciusive, charge, hypothecation, Hen on the Collaboration Land and/ or HMRPL BuA. ano /or
sales of HMRPL BuA from the Project/Collaboration Land in favour of the Lenders as detailed
below:
After the expiry of 300 (three hundred) calendar days from !he Effective Date, HMRPL.
shall be enti!led to mortgage, as above for an amount not exceeding Rs. 50 Crores
(Rupees Fifty Crores On!y) for meeting day-to-day and ProJect re\ated expenses, it is
being clarified that mortgage as above shall not be created to secure any non••Convertib[e
debentures or any other financial instrument that HMRPL ha~, issued or mB.y :ssue (except
if such non-convertible debentures / financial instruments are for working capital and/or
construction finance) or for any other borrowing except where such borrowing is taken for
meeting day-to-day and/or Project related expenses, Provided however HMRPL shall not
be entitled to create mortgage if payment at Stage 2 of Clause 5 1 of this Agreement has
not been duly received by !REO even though Closing Mi!e~\tone - 2 has been achieved
to the satisfaction HMRPL,
(ii) tn the event !REO has received all amounts of IFRSD up to and including Stage J of
clause 51 below, HMRPL shall be entitled to mortgage, a,s above, upto an arnount not
exceeding Rs, 100 Crores (Rupees One Hundred Crores Only'), mclud'ing the amount of
any borrowing as per 3.12 Ci) above, for meeting day-to-dny and/or Prowct related
expenses, !tis being clarified that any borrowing as above, shali not be cre:ated tc secure
any non-convertible debentures or any other financial instn.. ment that HMRPL has issued
or may issue {except if such non-convertible debentures / financial instruments are for
working capita! and/or construction finance) or for any othe:r purpose except where sucll
borrowing is taken for meeting day to day and Project related exp,1nses.
!t ;s bemg further clarified that in no event the mortgage to be created under 3 1? (,;, &
3, 'i2 (1i) above si1a11 exceed a sum of Rs '100 Crores (Rupees One Hundred Crorcs
and shali only be created by way of depositing and/or actual andlor by way of consti ucXve
delivery, the origina! title deeds and documents; and not by way of registered mortqaqe
fiv) Before creation of any mortgage as per 3, 12 (i) & (ii) abo·✓e, HMHPL shall duly 1ntinatc
!REO giving details of the mortgagee and true copy of sanction letter issued by the: Lenci er
from whom HMRPL intends to borrow for the purposes as detailed above Such snrction
letter/agreement shali have:
ORNAME.NT.A.L BTVS BUI LOWELL ADSON SOFTW/\HE BASE EXPORTS HERi f AGE 1viAX
REALTORS PRlVATE UMITED PRIVATE UMITEO PRIVATE LIMiTED f~CA\ TfCH
PRNATE Pff\/ATF
Litv1iTED UMlF'O
COLDEN Hl ENERGY BULLS REAL TORS COMMANDER

RE:ALTORS PRIVATE PRIVATE UMffED REALTORS PRIVt,l'E
BU\LDEr~s UfvHTEO LIMITFO
PH!VATE:
LIMITED
&
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319
a) an express provision that the loan can only be~ used for day-to-day and/or ProJect
related expenses and that the amount secured by the mortgage as above sha!I in
no event exceed Rs, 100 Crores (One Hundred Crores Only) plus applicable
interest and other charges thereon,
b) Language/provision/agreement to the effect that ir the event this Agreement i'.'1

terminated for 1Nhat so ever reasons. IREO shall have the absolute right but not
an obligation to pay the outstanding amount including all pre-payment chartJe:;.
interest, penal interest etc with respect to the borrowing and on rec(iipt of such
amount, the Lender shall release the mortgage so cri,:wtEid, remove the charge
that may be recorded under the Companies Act, 2013, issue a no•dues certificate
and deliver the same to !REO and handover the original of title documents that
may be deposited with it to !REO and if such title documents are deposited w1tt1
a trustee, issue written instructions to such trustee to release such title dccwnents
to IREO and !HEO alone
(v) HMRPL agrees that the shareholders of HMHPL as of the Effective Date, shall continue
to own at-least 76% ownership in HMRPL, and any decrease in shareholding below 76%
would require the prlorwritten consent of lREO, However, shareholders of HMRPL shall
be free to change inter-se shareholding of HMRPL without any intimation/consenl of
IREO.
Notwithstanding anything else contained in this Agreement. and it is clanfied for the sake
of abundant caution, that on and from the date that IREO is in receipt of an1ount of IFRSD
up, to anci lncluding Stage 4 of Clause 5.1 {Le 4,01 ,50,00,000/- (Rupees Four l,undred
and One crore and Fifty lacs only)), HMRPL shall be free to mortgage the Prn1ect Land
without ;;my limitatianslrestrlctions/!REO imposed conditions regarding, inter afia rnnount.
mode of mortgage/securitization whatsoever and in whatever manner deemed fit by
HMRPL including but not limited to by way of registered n-ortgage
HMRPL shall be solely liable and responsible to repay the principal amount v:ith
intorest and any other charges associated with the said loans/ credit fac!Hties ava:leci from
the Li,mders without any responsibility or liability of IREO in this reg;irc!
3.1 ;z 1 To secure ff:)fUnd of IFRSD by IREO to HMRPL and/or for discharging any HMHPL Obliqalions
and /orto secure the performance of obligations oflREO and land Owners under this /\greement
Ol~NAME:NT,t\L BTVS BUILDWELL ADSON SOrTVvl\RF BASE EXPORTS HE::f~l 1i\(,[ Mi\X
REALTORS PRIVATE LIMITED PRIVATE LIMITED PRiVATE UMlTED REALTFCH
PFilVATE PF!i 1/1\TT
UM!TEO LIMITED
GOLDEN HI ENERGY BULLS REALTORS COMMANDEf~ IREO PRIVATE

\/IE'vV H.EALTORS PRIVATF PRIVATE LIMITED REAU Of<.S Pr{IW.TE
BUil DEH.S UM!TEO UMlTED
PHIVATE
UMl1T:O
&
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320
HMRPL shalt be entitled to mortgageisecure the IREO Receivables m favour of the Lender as ,t
may deem fit provided amount of IFRSD as per Stage 4 Clause 51 has b,~en duly received by
IREO.
Adeauate authorisations for the above will be provided to HMRPL in U11s regard under the
HMRPL GPA Further, the Land Owners and IREO agree and undertake to sign anci/ or execute
all thE': necessary documents, agreements, deeds, declaration, no-objection ceriificates etc. in
favour of such Lender(s) and/or HMRPL, if required, forthwith on being requested by HMRPL
Provided always, Land Owners and lREO shal! not provide any personal! corporate guarantee
for such financing.
3.13 Construction and development of EWS Units:
3.13 . 1 !n accordance with the Zoning Plan, it is currently required that 15% of the total dwe!Hng units
shall be of economically weaker sections of the society ("EWS Units"). lt is agreed between tr:e
Parties that 15% of the total dwemng units of the Project wili be EVVS Units ("Collaboration
Land-EWS Units"), which wm be constructed by HMRPL on the Collaboration Land, and similarly
15% of the totat dwelling unlts of the iREO Project will be EWS Units ("IREO Principle land·
EWS Units"), which will be constructed by !REO on the IREO Principle Land or any other land
(except CoHaboration Land) as permltted under Applicable Law. IREO and HMRPL agree that
the current stipulation of 15% of the total dwelling being reserved as E\JVS Units is subject to
subject to upward or downward revision in the future in acconj,,rnce with Applicable laws
Accordingly, !REO and HMRPL shaH construct such higher or lower number of EWS Units m
respect of the IREO Principle Land-EWS Units and Co\!aboration Land-EWS Units as per
Applicabfe Laws then prevailing. The Parties undertake to adhere to all the conditions as laicl out
in the Zoning Plan with respect to the E\JVS category with rnspect to the number and size of
dwelling units under EWS category to be built on the Co!laborntion Land and the IREO Principle
Land, or any other !and (except Co!lahoration t.;::i.nd) as oerm1tted under Applicable Law.
3.13.2 HMRPL shall construct EWS housing on the Collaboration Land sc1bject to overall density for tt'1e
CoHaboration land not to exceed 3,562 number of persons at the Collaboration Land or such
higher density as may be permitted under Clause 2.8 herein and HMRPL aione shall be entitled
to all sale proceeds resulting from sale of such EWS area
3.13.3 HMRPL shall be entitled to locate the Collaboration Land-E\NS Units on the Co1:aboration Land
ORNAMENT/IL BTVS BUILDWELL ADSON SOFTWARE BASE EXPORTS HERITAGE MAX
REAL TOHS PHlVATE UM!TED PRiVATF UMITED PRtV!\TE UMITED REALTEC!I
PRIVATE PRIV.1\TE
UMITEO LIMITED
GOLDEN HlENERGY BULLS REALTOF{S CCMMANDER IREO Pf~IVATE

VIEW REALTORS PRIVATE Pl~IVATE LIMITED REP\l TORS PRIV.t\TE
BUILDERS UMITE0 LfMITFD
PRl\/J\TE
UM!TED
&
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321
as per its sole discretion and the Collaboration Land-EWS Units sh,alt be shown on builc:Ln9
plans for the Collaboration Land.
3.13.4 Similarly, IREO shal! be entitled to locate the IREO Principle Land-EWS Urnts on the iands other
than the Collaboration Land i.e. the IREO Principle Land and/ or a,1y oth1r lands. as deemed tit
by IREO, in compliance with Applicable Laws. Accordingly, the building plans to bE1 prepared for
the IHEO Principle Land to be prepared by lREO would aiso show the IREO Principle Land-EWS
Units in the said plans
3.14 The obligations of HMRPL and IREO with regard to the development of the Collaboration umc
may bE, further defined I demarcated as mutually agreed between 1REO and HMRPL upoc
sandion of the buHding plans prepared by HMRPL for the Project However, the same shall be
in lines of the parameters provided under this Agreement
4. AREA ENTITLEMENT & PAYMENTS
4.'1 ln consideration of the respective obligations that IREO and HMRF'L shall undertake on the
Collaboration Land, the entitlement of lREO and HMRPL to Sale;Jble Area to be developed or·
the Collaboration land shall be as under -
{i) 22% (twenty two percent} of the Saleable BUA (calculated in square feet) in the Project
shall belong to IREO, along with proportionate car parking spaces and the proportionate
interest in the underlying Coiiaboration Land ("!REO's BUA") !REO's BUA shall be
demarcated in accordance with Clause 4.2 beiow
(ii) 78% (seventy eight percent) of the Saleable BUA (calculati::d :n square feet) in the ProJcct
sha!\ belong ro HMRPL, along with proportonate car parkmg spaces and the
proportionate interest in the underlying Collabormion Land ("HMRPL's BUA")
4. 2 The commercial Saleable Area en@e,nent in addifor: to the residential constructior:

available/constructed/permissible on the Collaboration Land shall belonQ exclusively to HMFPI.
as part of HMRPL's BUA to the exclusion of IREO, and HMRPL shaH be cmtitied to all rece1vabies
from the same,
4.3 It is agreed and understood that HMRPL's BUA and IRf:O's ElUA sh2 1I be demarcated on the
final buiiding plans of the Project by mutual consent However. -lMRr,L sha!! t2.ke lead in sud,
ORNi\MENTAL BTVS BUIU)WELL 1\DSON SOFTW;\RE BAS,::: EXf'OfHS HERlTAC;F MAX
nEALTORS PRIVATE LIMITED PRIVATf LIMITED PRIV,'.\TE LIMiTED HEAL TECl 1
PRIVATE PRIVATE
UMITED UM!TFD
GOLDEN HI ENERGY BULLS REALTORS COMMANDER

VtEW REALTORS PRIVATE PFff✓ATE UMITF:D REACORS PRIVATE
BUILDERS UMlTED LIMITf"T;
PR1V.AJC:
UMITED
&
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322
demarcation. Before such demarcation, HMRPL shall issue a notice to IREO stattng that it
intends to dernarcate the Saieab!e Area along with the proposed demarcation. If the consent is
not received from lREO within such 60 days, it shall be considerec as deemed consent The
Parties will record the understanding in an agreed format
4.4 Each Party undertakes to dispose, sell, transfer or otherwise deal ,vith their respective built-up
areas as mentioned above in accordance and in complete compliance with the terms of this
Agreement, and enter into agreements with the prospective purchasers as ,Jttorneys of the Land
Owners, and receive the fuH and complete proceeds in the ma.nner as per the agreed terms and
give receipts and hand over ownership and possession of the Saleat::fe Area (as attcirneys of the
Land Owners) of the Project falling to their respective shares to the purchasers / al!ottees in
accordance with and in complete compliance with the terms ot this Agreement
•15 The brokerage on IREO Bu/\ 1Ni!I be paid by !REO The mechanism fer the s1ame shall be detailed
out in the Escrow Agreement!.
5 REFUNDABLE SECURITY DEPOSIT AND ESCROW
5.1 As security towards cornpliar.ce of its obligations under this Agreement, HMRPL shall place an
Interest Free Refundable Security Deposit aggregating to Rs 4,299,000,000/- (Rupees Four
Hundred Twenty Nine Crores and Ninety Lacs Only) ("lFRSD") with IREO in the following
manner:
[ '
"
i Stages
I
Il
Amount (lNR)
1 .\
.!
i
. (/) Compfetion "at Re-scheduling""
~
2,00.75 00,0001· (Rupees
to the satisfaction of HMRPL. Two Hundred Crore and Seventy
Fuifi:menr of following Conditions Precedent Five Lacs only) to be paid on the
Closing Date -1 .
a) Ali License are valld and subsisting or
r~,r:c\vat for 2n1rl aH re:quls.ite
fees relating to the same have been
paid
[The milestones rnentioned in (i) (1fl(i (ii) above
are col!eclive!y referred to c1s the ''Closing
Milestones-1 ")
ORNAMENTAL BTVS BU!LDWELL /,DSON SOFTVvAF~E BASE f:XPOR fS HE.RlT;\GE ivP.X

REALTOF\S PRIVATE LIMITED PR!V;\TE UMITED PRIVATE LIMlTED REAL TECH
PRIVATE PRIVA.TE:
LIMITED LIMiTED
GOLDEN HI ENEl~GY BULLS F~Ef\LTOf~S COMMANDER

VIEW f~EALTORS PHI\JATE Pf~lVATl: LIMITED RFALTO~S PRIVATE
PHiVATE
LIMITED
&
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323
COLLABORATION AGREEMENT
This Collaboration Agreement (this "Agreement") is made at Gurgaon on this 6th May, 2013
amongst:
lREO PRIVATE LIMITED, a company incorporated under the Companies Act, 1956 and,
having its rcgistcri;:d office at A· 11, l st Floor, Neeti Bagh, New Delhi-! 10049 (hereinafter
referred to as "IREO'\ which expression shall, unless repugnant to the context er meaning
thereof: be deemed to include its successors and administrators) actmg through its authorized
signatory Mr, Sharad Agrawal, duly authorized vtde its board resolution dated 6th May, 2013,
being Party oftbe FIRST PART
AND
WATSONlA DEVELOPERS PRIVATE LIMITED, a company incorporated under the
Companies Act, 1956 and having its registered office at 5th Floor, ·Mahindra Towers, Worli,
Mumbai·· 400 018 and branch office at Mahindra Towers, 2A Bhikaji Cmna Place, New Delhi-
1!0066 (hereinafter referred to as "Wl)L", which expression shall, unless repugnant to the
context or meaning thereof, be deemed to include its assigns, successors and administrators)
acting through its authorized signatory Mr. Suhas Kulkarni, duly authorized vide its board
resolution dated 6th May, 2013, being Party of the SECOND PART
AND
ORNAM.ENTAL REALTORS !>RJVATE L!MITim, a comp,my incorporated under the
Companies Act, 1956 and having its registered office at A-11., First Floor-, Neeti Bagh. New
Dethi - l l0049 (hereinafter rnlein:d to as ''Project Land Owner-1", which expression shall,
unless repugnant to the context or meaning thcreot: be deemed to include ils suci;essors ,m<l
administrators) acting through it:; authorized signatory Mr. Amber Sajid, duly authorized vide
it'3 board reso!utiun dated 6th May, 2013, being Party ofthe THIRD PART;
AND
BTVS BUILDWELL PRIVATE LIMITED, a company incorporated ur..der the Companies

Act, 1956 and having its registered omce at C-4, First Floor, Maiviya Nagar, New Delhi -
l l 0017 (hereinafter referred to as ·'Pro,icct Land Owner-II", ,vhfoh expre ·sion shall, unless
repugnant to the context or meaning thereof be deemed to include its successors and
administrntors) acting through its authorized signatory Mr, Amber Sajid, duly authorized vide
its board resolution dated 6th May, 2013, being Party of the FOURTH f'ART;
AND
.{)i
I~ LA
Watsonia Developers Private
Limited·
I~
Ornanieo~I RenHor~
,\
lrl'VS Utii~Uwcll l'riva!e
lreo Private Limited l'rivate dmited Limited
/\ .,
f 'I
1l
Re,l!tvrs i>rivat,'
Limited t
Bas~ Exp I~ I'rivat~
Adson S/fftw~t Private 1.imitell
Aspirant jlilders
f>rtvatc Limited
Bulls
l.imited
!l
Fiverh·ers ·ilwnship
Privat., l,ii~ed
,;,,nw«
Limited
,,:,J,,,nrd""
,' ulit~d
<.:omm:ind / r Realtors
(',·,vale
&
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Reg. No, Reg, Ye:ftr Book No. 324
551 2013-20!4
Thrn,~Snhas Kulkarni
~·
Saniay R Bhagat
w:rrfuTTT Tir,">'"1T 7£ITT1T ~~ F·.fi 1.r'<) \lm"i ~ 551 ::;;irst f~qfo1, 07/05/20t3 'tiT <il1';1 1: l f.:ir(::::r -r: 2,076 ,::i',
':l''d ';f: l39 tR ,z-Ji'F:'(!{1 f<h"l! ffl 0ifaftq;-q <if~[ ~ 1 ~ ';:f: 504 q;,
<141' "ffl''1f ~ , 11:fi'
~T 23 'TT 24 'TT• f+1,:v4n~ 1 r:fn <1\1 '"-it 1,:ftl]fum fcRIT ,,,ta\ ~ % ~ ~-<lrc'tn <t'r,,:a~ ~fa
1 1qrn'1 ,,~ ::r:rrf.:'\ ~H11i::F/f~TH ,?ii1J3l 'i'n ,~ f<r,i;r t I l V
~\:t~~
13 ~:ltf; ~;~ :;;,f'srcr:P:i
•u
Revenue Department Haryana HAR.JS-EX NIC-BSL
&
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325
BASE .RXPORTS PRIVATE LIMITED, a company incorporated under the· Companies Acl,
1956 and having its registered 0:ffice at 304, Third Floor, Kanchan House, Karampura
Commercial Complex, New Delhi - 1100 I 5 (hereinatler referred to as "Project Land Ovmcr-
IH", which expression shall, unless repugnant to the context or meaning thcreot: be deemed to
include its successors and administrators) acting through its authorized signatory l'vk Amber
Sajid, duty authorized vide its board resolution dated 6th May, 2013, being P,,rty of the FIFTH
PART;
AND
ADSON SOFTWARE PRIVATE LIMlTED, a company incorporated under the Companies

Act, 1956 and having its registered office at A-l 1, First Floor, Necti Bagh 1 Ntw Delhi -
110049 (hereinafter referred to as "Project Laud Owner-fV", whkh expression shall, unless
repugnant to the context or meaning thereof: be deemed to include its successors and
administrators) acting through its authorized signatory Mr. Amber Sajid duly authorized vide
its board resolution dated 6th May, 20!3, being Party of the SIXTH PART;
AND
ASPIRANT BUILDERS PRIV ATJi: LIMITED, a company incorporated unckr the

Companies Act, 1956 and having its registered office at 305, Third Floor, Kanchan I l,)llcic.
Karampura Commercial Complex, New Delhi - l 10015 (bercinafler refr,rred to as "Project
Land Owncr-V'', which express1on shall, unless repugnant to the context or meaning thereof,
be deemed to include its successors and administrators) acting throt1gh it:; ,iuth()rizcd .signntory
Mr. Amber Sajid, duJy authorized vid(, its board resolution dated 6th May, 2013. being Party of
the SICV,ENTH PART;
AND
HlJLLS REALTORS PRIVATl: LIMITED, a company incorporated under the Companies

Act 1956 and having its registered office at A-11, First Floor, Neeti Bagh, New Delhi -
l l0049 (hereina(terreforred to as "Additional Land Owner-I", which expression shall, unks;;
repugnant to the context or meaning thereof, be deemed to inc.lude its successors and
administrators) acting through its autll()rized signatory Mr. Amber Sajid duty authorized 1·ide
its board resolution dated 6th May, 2013, being Party of the KIGHT PART;
AND
FJVERJ[VF'.RS TOWNSHIP PRrVATE LIMITED, a compa,1y inn,rpornted und;;r ths:

Companie:,; Act, 1956 and having its registered office at 305, Y·1 floor, Kanchan ll0us,'.,
. a
Karnmpf_ra?ommercial C."omplc~.:, New Delhi ·· 110015. (hererafter referred to as "Ai.dditioual
1•
~/ ·
lrcn l'riva.te Limited
iYat,onia~~loper~ I'rh•ate
Limited . . Private Utt~d
Ornament~ Realtors JJTVS Hoi'. well Priv:.1tc
Limited (J!
11 Private 'J . . 1/ Hulls Re' tors Private
Limited
.---.....
l\
Ras,: f:xprlhs
Adson Sntl\arc l'rirnte Liniitc<i
•'1\
Aspirant ~)1ilders
Prhate Lill\ited
1
I.imited 1•
I
Fiveriver~ "fownsllip Fiverivers ~[)evek,pers Private Commandei1Ri:,1 ltor~
Umitcd fl)
l'nvaic l~\nitcd
,, Private Linf!tcd
&
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326
Land Owncr-11", which expression shall, unless repugnant to the context or meaning thereof~
be deemed to include its successors and administrators) acting through its authorized signatory
Mr. Amber Sajid duly authorized vide its board resolution dated 6th May, 20 !3, being Party of
the NlNTH PART;
AND
.FIVERIVERS DEVELOPERS PRIVATE LIMITED, a company incorporated under the

Companies Act, 1956 and having its registered office at 305, Third Floor, Kanchan House,
Karampura Commercial Complex, New Delhi - t 10015 (hercinatter referred to as "Additional
Land Owner-III", which expression shall, unless repugnant to the context or meaning thereof,
be deemed to include its successors and administrators) acting through its authoriz1,;d signatory
Mr. Amber Sa,jid duly authorized vide its board resolution dated 6th May, 2013, being Party of
the TENTH PART;
AND
COMMANDER REALTORS PRIVATE LIMITEU, a 1,;ompany incorporated under the

Companies Act, 1956 and having its registered office at A-l l, First Floor, Neeti Bagh, New
Delhi - l I0049 (hereinafter referred to as "Additional L.md Owner-IV'', vvhieh expression
shall, unless repugnant to the context or meaning thereof: be deemed to incwde its successors
and administrators) acting through its authorized signatory Iv1r. Amber Saj id duly c:uthorized
vtde its board resolution dated 6th May, 2013, being Party of the ELEVENTH PART;
("Project Land Owner,,I" to "Project Land Ov,mer- Y" are hcrcinnftcr jointly reforrec'. to as the
"I'roJcct Land Owners")
("Additional Land Owner-I'' to "Additional Land Owner-IV'' arc hereinafter joimly referred to
as the "Additional Land Owners")
("Project Land Owners' 1 and the "Additional Land Owners" are herc:ina.fter jointly referred to
us the "Land Owners")
(All patties to this Agreement i.e. the Land Owners, IREO and the WDL an:; hereinafter
collectively referred to as the 'Parties' and sometimes individua!ly referred to as a "Party").
WHEREAS IREO HAS REPRESlrnTED TO WDL THAT:
A) The Land Owners are the owners of certain parcels of lands, which in aggregate form n
contiguous parcel of land ad-rneasuring 1.58 Kanai I Marla i.e. 19.75625 acres in
Village; Behrampur, Tchsil; Solma and District Gurgaon in Sector - 59, Gurgaon
\hereinafter referred to J_asthe "Total Lands"). The Tottal Lands arc more irrticularly
'%·
ii {'I'·. ') t ~
Watson ht J)evelo(}en Private .
Ornamenta,r
I
j ea!1crs B'l'HS
r.
Buti.\~l we ll priv
. ate
Im> Privat~ Umited Limited I Private Limited Lhuikd
1 ll / t
1, .
H~s': Exp!r,t~ Pnvatc
IJ
11 . . .
. 1h
AsJHflllll !~~.jldcr~
h
Bulls Reni~•>rs l'ri'l'nte
Lmntcd )' Adsun Soft~\un, Pnvaf<: L1r111tcd Pnvah! Lumterl Limited !;
I \
Fivcrive1J\·uwnship Fivcrivcrs !evcfop~rs Privll!e
~
Conumm<l{r Realtors
J>rivnte Lipiitcd Limited \\ Private Litted
~
&
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327
described in Schedule-I to this Agreement and delineated on the plan in Purple and
Green colour, which is Schedu!e-11. The Project Lands (as defined hereina±kr) and the
Additional Lands (as defined hereinafter) are parts of and together constitute the Total
Lands.
B) The Land Owners are vested with absolute ownership and dear and marketable title to
the Total Lands, free from any Encumbrance (as defined herein) with absolute and
complete posscssory rights and entitlements, The Land O,.vn0rs are the recorded owners
and in possession of the Total Lands in all governmental records including the Record
of Rights. The description of title and the cummt mutations in the Record of Rights
vesting the Total Lands in favour of the Land Owners are detailed in Schi;du!e-IV to
this Agreement;
C) The Land Owners have granted abso.lutc development rights to IREO in respect of the
Total Lands by and under the Development Agreements detailed in Schcdnk:-IV of this
Agreement (the ''Land Owners-IREO Development Agreements"), The Land
Owners-rREO Development Agreements have been duly cxl':cute<l und are binding and
irrevocable in nature, There are no facts ur circumstances in existence and no events
have occurred which render the Land Owners-IR8O Development Agreement void or
voidable, or repudiated or revoked or frustrated, or capable of rescission k,r any renson,
and in particular without limitation by reason of lack of consideration, influence,
coercion, duress, default, fraud or misrepresentation. As a concomitant part of the rights
vested in IREO under the Land Owncrs-lREO Development Agrt~ements, lREO rs in
possession of the Total Lands. Further, IREO is vested with the entitlement to grant the
development rights to WDL as granted under this Agreement, subject to a prior
intimation to the Land Owners.
D) The Director Town and Country Planning, Haryana ("UTCP") has granted a License
bearing no. 16 of 2008 dated 3 l. st fanu<try, 2008 (the "Lkense'') under the I laryana
Development and Regulation of Urban Areas Act, 1975 and Rule:; l 976 fr)r
development of a Grnup Housing Colony on lands measuring 17.55 acres (the ''Project
Lands") out of the Total Lands. 'fhc Project Lands are more particularly described in
Schedule-I to this Agreement and delineated on the plan in purple colour, which is
Schedule-II to this Agreement. Th,: License has been renewed up-to 30* January, 20 l 4
by and under Memo no. LC-1042-JE (B)/2012./9113 dated 2th May, 2012 issued by the.·
DTC"'P (the "License Renewal Memo"). The Prqjcct Lands are owned by the Project
Land Owners,
E) An area measuring 6.118 acres out of tbe Project Lands is coming under roads. H.encc,
the actual area over which the Project (as defined later) can be developed is l 1.5 acres.
Details of the lands that arc coming under roads is provided in Schedule-L The Su~jcct
\.and.s (as defined hereinatter) are a contigumts land parcel out Qf the Proj~·ct Lands.
(. ><. l I
(}?:
✓,f;jX ' · ,6/\lopers 1'rm1tc
Wntson1a !)eve · it '
() rnamcnta~1,ca,tnr,; IJ·1•vs··
, • ll. m·1[,we, 11 I'rwatc
.
lreo frivate Limitetl Limited Privatr Limited Limited I _r
H
n Private ' H
i !If
1
B:1s~ Expo~{~ _ i: . . . As~inmt lj/1_ildcrs B:11!s Re~ltors l'rivatc

I,1mrted \J Adson Snttwarc ·, nv11tc Lumtctl · Pnvate L111'!1ted L1m1tcd
t\'
Fivcrivcr~township
I
Fiverivers De,,cJ pcrs Private
l
C:ommam~lir Re~ltors
Private Umi!cd I .imitcd t•rivute 1; ited
'
&
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328
The Subject Lands have a proper access through a proposed motorable se<:tor road
having a width of 60 meters (with 12 meter wide service road) and a proposed 24
meters wide road. No road traverses through the Subject Lands, exi;ept a revenue rasta
of 11 feet width as provided in clause 9.2.2 (f) below.
F) As per the prevailing Applicable Law, the total residential FSI available/permissible on
the Project Lands as part of the Project (defined hereinafter as the development of
group housing colony and all other appurtenant faci!ities, amenities and infrastructure
required / permitted to be developed on the Project Lands under the License and
Applicable Law and as per the norms s•~t out in the Zoning Plan) i.s l ! 97268 square foct
equ:ivalcnt to l l l 230 square meters ("Total Project FSI").
AND ,vHEREAS IREO is developing various other projects and townships around the Project
and also undertaking infrastructure development works around the Project and selling units/
saleable area in the said projects. However, IREO is also keen to gai7 best industry practices
from other reputed developers, ,:vhich will assist in delivering good products in th,e market
This will also result in accelerating the process of development, which IREO intends to
undc1takc in the said area. Thus, IREO has been discussing wi.th WDL, wh@:: parent
· company: Mahindra Litespact~ Developers Limited, a part of Mahindra Group and an Indian
multinational group, has the requisite expertise and has undertaken and is cmTently developing
similar prQjccts across India, fbr de:vc!opment of a part of the Project i.e. Project-Subject
Lands (as defined later in this Agreement) as a single project, with WDL and IREO
undertaking separate and specific construclion works, activities, roles and responsibilities on i
with respect to the Project-Subject Lands.
AND WHEREAS IREO being vested with absolute development rights in respect of the
Project under the Land Owners-[REO Development Agreements, has agreed to grant and
transter part of its obligations, right:;; and entitlements in favour of WDL, to enable WDL lo
undertake lts part of the deVe!opmenL and e<.mstruction activities on the Project-Subject Lands,
as per the terms and condit[ons ot'this Agreement. The Parties will be vested with separate and
identifit1d rights, entitlements and obligations as provided herein.
NOW TlfEREFORE, IREO and \.VDL, with the Land Owners being part of the confirming
party hereto, have, in accordance with the terms of this Agreement, agreed to come together to
develop the Project-Subject Lands on a portion of the Project Lands i.e. lands adm1.:a:,'Uring 46
Kanals 7 Marlas (5.794 acres) out of the Project Lands (hereinafter rnfomxl to as tht: "Subject
Londs") and the Additional Lands (as defined hereinatler), subject to the conditions lLi set out
in this Agreement. The Subject Lnnds are more particularly described in Schedule-I to this
Agreement: and delineated in purple colom on the plan whrch is Schedule-Hf to this
Agreement.
9;' i)
/,
$,..,1/\
Watsonia Devbtop,:rs l'riv·atc BTVS Bui/Bwcll Private
Lh11ited Umittd '
.,
I
Ii
~~} Bulls ReaHJ, Private
Adsnn Softwdj\, Private Limited Limited /f !
i
l
Fiverivcrs ~evelopers l'rtvatc
Limit<!d ;
&
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329
NOW TllEREFORE, in consideration of the mutual. covenants, terms and conditions and
understandings set forth in thi.s Agreement and other good and valuable consideration, the
Parties with the intent to be legally bound hereby agree as follows:
1. DEFINITIONS AND INTERPRETATION
1. L Definitions - In this Agreement (including the recitals), unless the ccmtext otherwise
re,'<-iuircs, the following expressions shall have the fo!lowing meanings:
(i) "Additional Lands" shall mean and refer to lands measuring 17 Kanals and 13
Marlas (2.20625 acres), as more specifically detailed in Schedule~I and
delineated in Green colour in the plan attached as Schedule-II. The
Additional Lands arc a part of the Total Lands, and the Project Lands and the
Additional Lands in aggregate comprise of the Total lands.
(ii) "Additional Refundable Security Deposit" shall have the meaning ascribed to
it in Clause 8.2 (vii) herein.
(iii) "Affiliate'', shall mean in relation to any Party, any person that controls, is
controlled by or is under the common control with, that Party, as the case may
be and shall include the parent and subsidiary company(ies);
(iv) "Agn1emenf' shall mean this Collaboration Agreement including 111! Schedules
and Armexures attached hereto or incorporated herdn by reference, as may be
amended / supplcrrwnted by the Parties from time t<J tirne in writin,;;
(v) "Applieable Law'' sha.ll mean all applicable !a,vs, bye-law:;;, rnlcs, regulations,
orders, ordinam;es, nolifications, protocols, cedes, guidelines, policies,
notices, direction$, judgments, decrees, including the Foreign Direct
Investment poli,:ies, rules and regulations and other requirements or official
directive of any Govermnent:a! Authority or person acting tmder the authmily
of any Governmental Authorily and/ or of any statutory author 1:ty in India,
whether in etlect on the date of this Agreement or lhereaft.er;
(vi) "Approvals", means and refor to all permissions, including, no objection

certificates, clearances, permits, building sanction plans, sanctions,
exemption::;, approvals im:.:luding hut rwt limited to Airports Authority of
India, Pollution Control Board, Ministry of Environment & Forest, Fire
departm1;;nts, BR-HI, Mining, Forest, Indian Gret~1 Building Council, Arava!i
clearance, irrigation, Public Works Department, Indian Railways, Municipal
Corporation, National Highways Authority of India, Ground water clearance,
Haryana Urlxrn)(Dcvclopment Authority jppn'vals, Town Country an/.
;JJ-, 11 1~:
\Vatsonia o·eve\,;pers Prirntc Onmmenta! Realtors BTVS Huil~well Private
Limited Private Liniitcd Limited i
j Aspi,.nt tt~ild<O Bull, Ro,Jf rs .Private
,\dson SoftwJe Privaw Limited Priv11te Liiliited Limited '
'r: I
Fivcrivcr~ o~v)llopcrs
it l'rh'lltC Command.~
c Rtaltors
Limited ~ Private Li I cd
&
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330
Planning, local bodies, building plan sanction / approval, occupation

certificate, completion certificate etc., required from any Governmental
Authority or from any other person, as the case may be, for the acquisition,
construction, development, ownership, occupancy, operation, management,
leasing, disposal, transfer of or creation of third party interest and shall
include without limitation all approvals relating to or pursuant to sanction of
layout plans, building sanctioned plans, environment, cutting of trees, drawing
of water, height, commencement certificates and the occupation certificates
required in relation to the construction, development, occupation and sale of
the Project-Subject Lands;
(vii) "Balance Security Deposit" shall have the meaning ascribed to it in Clause
5.1 (ii) herein;
(viii) ''Density-Additional Lands" shall mean 473 persons;
(ix) "Densily-Project Lands" shall mean the total density available over the Project
Lands, being 4712 pers(ms for the Project Lands;
(x) "Density-Remaining Lands" shall mean the total density out of the: Density-
Project Lands that shall be available / utiliied for construction / development.
on the Project-Remaining Lands over the Remaining Land!>, being l 800
persons;
(xi) "Density~SubJcct .Lands" shall mean the total density out of the Density-
Project Lands that shall be available / utilized for construction / development
on the Project-Su~ject Lands over lhe Sul::jcct Lands, being 29 l 2 permns;
(xii) "DTCl'" shall mean the Director, Town and Country Planning, Haryana.
(xiii) "ECC" shall mean and refer to Electricity Connecti(>n Charges;
(xiv) "I::DC" shall mean and reter to External Development Charges.
(xv) "Effective .Date" shall mean the date of registration of this Agreement and
WDL-GPA;
(xvi) ".Encumbrance" means any mo1tgage, pledge, equitable interest, assignment by

way of security, conditional sales contract, hypothccation, right of other
persons, claim, security interest, encumbrance,. title defect title rett:ntion
agreement, voting trust agreement, interest 1 option, Hen, charge, cmnmitmcnt,
restriction or limitation of any nature, whatsrever, including rest,iction Oil
freo l'rfrutr "Limited

w,•••
Limited
/l.,,,,N ' """ orn,m,n<,ti""'~
Private Limited
.i
BTVS .,,.,/w,11 Pd,,.,
Limited ,
I
I
N 1,1
i
Base ExpoftS Private i~ Aspirant Builj_,ers Bulls Reall~rs Pr.ivatc
Limited AdsM Softw,re Private Limited Private Umt1ed Umited
/i
FivcriverJ1rownship Fivcrivcrs l)ielopcrs l'rivate
1
Commander . ealt,.rs
l'dvatc Lilh,tcd Limited / Private l ,imiJd
I
&
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331
ust:, voting rights, transfet\ receipt of income or exercise o!' any other attribute
of ownership, right of set-off, any arrangement (for the purpose of, or which
has the effect ot granting security), or any other security interest •.>f any kind
whatsoever, or any agreement, whether conditional or otherwise, to create any
of the same.
(xvii) "Escrow Account" shall have the meaning ascribed to it in clause 5 .1 (i};
(xviii) "EWS Units" shall have the meaning ascribed to it in clause 3. l 4. l below;
(xix) "FSI" means Floor Space Index;
(xx) "FSI-Additional LamJsH shaJl mean 120000 square foct (equivalent to l l !48
square meter) of FST out of the Total Project FSI;
(xxi) "PSI-Remaining Lands" sha.ll mean 457268 square foet (equivalent to 4248?
square metet:) ofFSI out of Total Project PSI;
(xxii) "f,'Sl-Sul:>Jeet Lands" shall mean 740000 square feet (equivalent to 68748
square meter) of FSI out of the Tota! Prt~cet FSI, as also provided in Clause
2.6 of this Agreement, and any addition to the same in accordance with the
terms of thi.s Agreement;
(xxiii) "Government Authority(ies)" shall mean any government authority, statutory

authority, government department, agency, comn1ission, board, tribunal or
court or any other law, rule or regulation making entity having or purponi:1g
to have jurisdiction on behalf of the Republic of India 1>r any state or 0tl:er
subdivision thereof or any municipality, district or other subdivision thcrcoL
including any municipal,/ HUDA/local authority/DTCP having jurisdiction
over any matter pertaining to the construction, development and ::;ah:: or tlH:
Prqject, Project-Subject Lands and the Project-Remaining Lands;
(xx:v) ·mMS' shall mean Interest Bearing Maintenance Security:
(xxv) ''lDC" shall mean and refer to Infrastructure Development Charges:
(xxvi) 'IFMS' shall refer and mean to Interest Free Maintenance Security;
(xxvii) ".1.RE:O's HUA" shall have the meaning assigned to it in Clause 4, 1 herein;
Wm,,;,
Limited
L,, l'dw«
1l
111
Ornam,:nt:ij' Realtors
Private Limited
i
llTVS B11i~lwcll Privat,
Limited ;
Ir r
I
""" s,,l" '""" Umi«d
Aspirant B~vl Iden
Private Lim tcd
!
.I
llulls Rciltors Priv;,tt,
Limited~
DJ dopers Private
~
Fiverivers Jownship Fivcrivers ComnrnndeJ Renltors
Privnk L.i~ited ;,imited Pdvate Lirrt\ted
&
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332
(xxviii)''IREO's Costs" shall mean any and all costs, charges, stamp duties, tees,
expenses or payments of any nature or description whatso0ver, towards the
following~
(a) towards 1REO Obligations under this Agreement.
(b) towards compliance of IREO Obligations of obtaining any Approval

required in respect of the entire Project as mentioned in tem1s of this
Agreement;
(c) tov-/ards compliance of IREO Obligations to obtain any re-approval,

renewal, extension or modification or
any Approvnl including the
License in respect of the Project in terms of this Agreement;
(d) all taxes, cesses, land revenue payable to the concerned authorities in
respect of the Total Lands during the construction and implementation
of the Project;
(xxix) "IREO Obligations" shall mean the following;
(a) IR.EO~Subject Lands Development Obligations;
(b) To incur all IREO's Costs;
(c) Not to do any act of omission or comm1ss1on in relation to the

Remaining Lands or otherwise that would prejudice the development or
construction of the Project-•Subject Lands or would have au effect of
withholding or denying permission to occupy the WDL's BUA or
IREO'sBUA;
(d) To construct and J0vdop Remaining L:.inds-E\VS Unit:-; mid School in

accordance with Clause 3.14.1 and 3. 15 below;
(e) To obtain all Approvals in respect of the Project in a timely rr::anner and
as may he required by WDL;
(f) To make best endeavour to shitt the revenue rasta out of the Subject
Lands in accordance with Clause 3.7. l below;
(g) To get the renewal of the Licence and a!J other Approvals b a timely
manner as per conditions as set out in Clause 3.7.5 below;
\ I
/2-y
ii
~
., (./
I
Ornamental ,~cnttnr~
Vi
BTV.>; Build~vell Private
lrc11 l.'riva\c Limited Private Umiled Limited
p
·i
Ilnse E:q:i~ts Private
r
Aspirant B~lllkrs
Limited , .\Csoo Sof<wJ P,WM, f.imito<l l'rivntc Limi~cd
fj ,· {
I
Fi,·uivcrs ~ownship Fivcrivcrs Devclo/ er~ PriYUlc
f:
l"rivatc LiJitcd Limited t C'omm:indei Realt,n-s
Pri.-atc Limited
&
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333
10
(h) To maintain the norms for FSl-Remaining Lands and Density-

Remaining Lands as prescribed in Clause 2.7 of this Af:_'Teeme11t;
(i) To permit WDL to enter upon and exercise such control over th<;; Subj<;;ct
Lands as required for the purposes of exercising the WDL Rights and
\\i1)L-Subject Lands Development Obligations;
(i) To require Land Owners to transfer title in Saleable i\nw of the WDL's
BUA. and the proportionate share in Subject Lands and ifrequired under
Applicable Lav-1 in Total Lands, in favor of the allottees or the WDL's
BUA and to exceute all documents thereof in a tirnc!y manner in
m:cordance with the contracts / arrangements between WDL and the
a[lottees / purchasers, at the cost, risk and expense of WDL;
(k) To execute all necessary legal and statutory writings, agreements and
documents for exercise of the WDL Obligations and WDL Rights and
for sale of the WDL's BUA, as and when and in the manner format that
may be required by WDL, and to require the Land Owners to do the
same:
(!) To pay service tax as may be applicable on this Agreernent;
(m) To maintain unencumbered title / cwvnership of the Land Owners on the

Total Lands;
(n) To refund the Refundable Security D1.'.posit to \,VL)L in acct,rdance with

clause 5.2 of this Agreement To rnaintain the bank in$lructions in
accordance ·with clause 6.2 (iii) for transfor o the Net Sak:; Revenue of
IREO's BUA to WDL at ail times;
(o) To ensure that the WDL GPA provided in nccordance \Vith Clause 3.1 l
of this Agreement and authorizations that may be provided in
fortherance to Other Documents subsist and continue at all times;
(p) To observe at all times all laws, regulations and notificuti,,m::; dealing
with all the workers engaged for the tREO-Subjcc1 Land::: Development
Obligations, including payment of their dues, wagc5, grntuity, cess,
taxes, benefits, claims, working conditions, safety, accidents,
complaints, titfgation in respect there.of;
(q) To observe and shall be responsible and liable for all customers/
aHottees of any units/area
A
I..i111i1cd
//
Adson Sof,are Private Limited
! '
Flveriver., DevJ•pcr~ Privilte
l.imired f
&
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334
1l
complaints, claims, litigation made/initiated by them with n:spect to

[REO's BUA;
(r) To be responsible and liable frlr all contractors, consultants, technicians,

engineers, persons (including its own employees), brokers, advertisers,
engaged for [REO-Subject Lands Development Obligation:, and or
IREO's BUA including payment of their bills, dues, salaries, fees,
taxes, benefits, claims, safety, accidents, complaints, litigation;
(s) To assist WDL to maintain the Pr(':ject-Subject Lund:, including the

Subject Lands Facilities ! Common Areas till hand over of the same to
the association of apartment owners as per Applicable Law, at the
request of WDL;
(t) To provide full assistance to WDL, at the rcqucs: of WDL, to manage

the Subject Lands and the property and facilities / common areas
constructed upon the Subject Lands as may be required under the
Haryana Apartment Ownership Act, 1983 or nny other Applicable Laws
and/or rules made there under;
(u) After occupation certificate of all construction in Project-Subject Lands

has been obtained, to obtain the completion certificate of the licensi.:
pursuant lo completion of the Project a::; may be required under the
Haryana Development and Regulation of Urban Areas Act, l 975 and
Haryana Development and Regulation of Urban Areas Rules, 1976;
(v) To comply with all the conditions contained in the Approvals as may be
obtained from time to time in relation to the implementation of the !REO
Obligations;
To comply with all other obligations as stated in this Agreement.
(xxx) "lREO Rights" shall refer Lo the rights, po,vers, entitlements, authorities that
[REO would h,tve to undertake for the discharge of its obligations and duties,
as spedfied in th]s Agreement, with regard to iREO-Subj,~ct Lands
Development Obligations and IREO Obligations, i.e. the following:
(a) To carry out the construdion / development of the lREO-Subject Lands

Development Obligations;
To appoint, employ or engage architects, surveyors, engineers,

(b)
contractors. )f
b-contra.ctnrs, labour, wlkmen, personnel (lilled and
{Y,, i!E
W1ttsoni11 DcY~fup1rs Private Ornamenialu~ealtcrs l:rIVS Buf!well P1ivatc
ln:o Private Limited Limited Private Lir.ited Limited I
l
tt
I,
Ba~c Expo
Limited
Private M
Adsim ~oftwarl'!'rivah: Limited
Jlilders
:\spinlllt
Private Umitcd
Bulls Rcallors l'ri¥ate
Limited
ii l
1
Fiverivcrs ·nil\'t1ship Fivcrivcrn l)~v tpcrs Privafo Commandtr Realtors
Private Limi~d Umit~d i/ 1'1 ivate Li,;iited
&
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335
l2
unskilled) in the manner specified in Clause 3.5 below or other persons

to carry out the IREO~Subject Lands Development Obligations and to
pay their fees, consideration, wages, remuneration imd salary of such
p<.:rsons in a timely manner:
(c) To exercise foll, free, uninterrupted and exclusive sale rights in respect
of the lREO's BUA in accordance with Clause 4.3 herein;
(d) To make applications to the concerned Government Authority or semi-

governmental authority in respect of Approvals required for the Project;
(e) To make payment and/or receive the refund of all deposits, or other
charges, foes to and from all public or Government Authorities or public
or private utilities, that may have been paid/ deposited by IREO;
(t) To deal with, appear before and file applications, declarations,

certificates and s11bmitf receive information with, as may be required
under the Applicable Law, any Government Authority ~L<; may be
necessary with respect. to Approvals relating t,) the Project and
implementation of the lREO Obligations;
(g) To ctmy out and comply with all the conditions contained in the
Approvals as may be obtained from time to time during implementation
of the IREO Obligations;
(h) To sell the Saleable Area forming part of IREO's BUA to any third
party, at its cost, risk and expense and to retain collect/ receive amounts
thereof in accordance with this Agreement;
(i) To execute all necessary, lug.al and statutor:r writings, ag,~~cmcnts and
documentations for the exercise of IREO Obligations and in connection
with tbe sale of IREO':i BUA;
(j) Generally to do any and all other acts, deeds and things that may be
required for the exercise of the lREO-Subject Lands Development
Obligations and 1REO Ohligations;
(xxxi) "IRED-Subject Lands l}evelopment Obligations" shall be as provided in

clause 3, 16 and Schedule-V herein;
(xxxii) "Laud Owners-IREO Development Agreements" shall have the meaning

~ ascribed to it in Recjtal C to this Agreement;/
v?..
Ireo Ptfo1te Limited
Watsonia
f,,irnitctl
Dctrs l'i-ivi1te Orm1n1cn!1 Rc11ltors
Privllte Limited
1t
RTVS Buil\~well Private
Limited
1
fl I (
.-\spiran ~huildcr~ Bulls Re.a~or., Private

Umi"d +
Ifase Ex ,rts Private
I'
//
A1t«m Soft\w'<\' Prim, l,lmied M,o<o 3tmi<ed Limited .
Nvcrivers Tow 1ihip Fiv,:river.~ De,lelopers Pl'ivate Cornman /er Realtvn

Private Limlte1q; Limited Private Lt1ited
&
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336
(xxxiii)"Lcnder" shall mean a third-party lender funding the development or

construction of the Project-Subject Lands or providing any refinancing
facility thereof;
(xxxiv)''Liceuse'' shat! mean the License No. 16 of 2008 issued by the DTCP vidc its
Memo dated 3 l st January, 2008 under the provisions of the Haryana
Development and Regulation of Urban Areas Act, 1975 and Rules 1976 for
development of the Project on the Project Lands;
(xxxv) "Liccns1; Rencwnl Memo" shall mean the renewal of the License as approved
by the DTCP vide its Memo dated 28 th May, 2012 under the provisions of the
I-laryana Development and Regulation of Urban Meas Act, l975 and Rutes
1976;
(xxxvi)"Net Sales Revenue" shall include tbe basic sale price, the preferential location
charges, car parking charges, club house membership charge;;;, EDC, me,
power backup charges, transfer fees, cancellation I frlrfoiturc charges, legal
charges, interest on delayed payments and all such other similar charges that
can be retained by a developer / promoter of a project of a similar nature.
except lFMS, IBMS, ECC and Other Charges;
(xxxvii) "Other Charges" shall include service tax, VAT and all other similar charges
that may be required to be transferred / deposited to a Government Authority
in the process of allotment / sale of the saleable area in the Project-Subject
Lands;
(xxxviii) "Other Documents" shall have the meaning ascribed to it in clause 9. I . t

belmv;
(xxxix)"Part Add.itional Lands" shall have the meaning ascribed to it in clause 8.:,
helmv;
(xl) "Part Additional Refundable Seenrity Deposit" shall have the meaning
assigned to it in Clause 8.3 (i) belmv;
(xii) "Pro,icct" shall mean and refer to the development of group housing <;olony and
all other appurtenant facilities, amenities and infrastructun.: rec1uircd
permitted to be developed on the Project Lands undt!r the License an.d
Applicable Law and as per the norms set out in the Zoning Plan:
j
~
Wtttsonia Developers .Private Ornan)elal Realtors
In:<} l'rivahc Limiktl Limited Private Limited
i1 I
Base Exrli~s l'rivate ll Aspirant !uilders Bulls ReJtors l'rivatr
Limited it Ad.~,:m Softwail Pri~·ate Limited Private Ll'iited LimitNl !,
FiveriverifTowns hip Fiverivers De) foptrs Private Cornman ·r Realtors

Private LHnited Limited t Private Li ' itett
&
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337
14
(xiii) "Project Lauds" shall have the meanir:g ascribed to it m Recital D to this
Agreement;
(x.Hii) "Project-Remaining Lands" shall mean and include development of the

following on the Remaining Lands as part ofthe Project;
(a) Residential group housing by consuming FSI-Remaining Lands and

Density-Remaining Lands;
(b} Such number of car parking spaces as are required lo be provided for
the number of d,velling units that may be constructed on tht~ Remaining
Lands and as per the norms set out in the Zoning Plan;
(c) Remaining Lands-EWS Units;
(d) Infrastructure development specific to the Remaining Lands;
(e) Development/ construction of School in accordance with dause 3.l5

below.
(xliv) "Project-Sub_jcct Lands" shalt mean and include development of the following,
on the Subject Lands as parl of the Project;
(a) Residential group housing by consuming FSI-Subject Lands and

Density-Subject Lands;
(b) Community centre / club house for use by the occupants of lhe
residential development on the Subject Lands, as m,w be conceptualized
by WDL;
(c) Car parking spaces that are constructed in accordance with th-:
conceptualization of the Project-Subject Lands, subject to a minimum of
what is required under Applicable Lav,1 / Zoning Plan;
(d} Other amenities and focilitics appurtenant to and permissible to bt:

dcve.loped as part of a group housing project under applicable lmv, such
as tennis c.omts, swimming pools, open areas/ garden spaces etc, as may
be conceptualized by WDL;
(c) Subject Lands-EvVS Units;
(f) Development / construction of School ii~ accon. lan<"c with claie 3.15 1>1
w,.oofu
Umitecl
0,pm ,
f<;ffl~ Offl,m'°"~"'""'
Private Ljm,ted
UTVS R,i,.,11 Ph,s«
timitcd
1
11 1, ,
~\ Aspirant ~uildcn Bulb Rt,)·,rs Private
Ad.son Softw:,~ Private Limited Private til\,itcd Limited 'IT
'i f
Fiverive1·s D~v { h,pcrs Private Commaml,ir Realtor$
Limited 1• Private 1.lmited
&
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338
15
this Agret:;ment;
(g) Infrastructure development specific to the Subject Lands;
(xlv) "Refundable Security .Deposit" shall have the meaning ascribed to it in clause
5.J below;
(xJvi) "Remaining Lands" shall mean the clevelopablc lands otht:r than the Subject
Lands out of the Project Lands. The Remaining Lands are more particularly
descr.ibed in Schedule-I and delineated in Green color in the plan attachc<l as
Schedule-HI. The Remaining Lands, the Suqject Lands and the land
measuring 6.1 l 8 acres consumed for roads, together comprise of the Project
Lands;
(xlvii) "Remaining Lands-EWS Units" shall have the meaning ascribed to it in

Clause 3.14.l below;
(xi.viii) "Saleable Arca" shall mean and include the carpet area (wall-to-wall), an:a
under the walls/ wall cladding, proportionate share of area t<) be utilized for
common use and facilities, such as terraces, lobbies, atdums, AHU rooms,
shafts, passages, corridors, refuge an:a, :;tilts, common amenities and services
like electric sub-statiot1, stand-by generator, fire fighting 1..:quipments, building
management systems, water tanks, \Vashrooms, sha(b, mad1ine rooms,
staircase, lifr, wells, security booths, common room:;, common corridor~, open
spaces and the like or any other service area useli for common services etc., as
may be calculated for all apartments/ units in the entire Pn'.ject-Subject L~,nds,
which calculations shall be made by WDL;
(xlix) "Subject Lands" shall have the meaning a':icribed Ll it in the Rccltals to t!1is
Agreement. The Subject Lands arc a contiguous parcel of \ands out of the
Project Lands. The Subject Lands, the Remain ng Lands and the lands
measuring 6.118 acres consumed for roads, together c;ornprise of the Project
Lands;
(l) "Subject .Lands~EWS Units" shall have the meaning ascribed to it in Clause
3.14.1 below;
(Ii) "SubJect Lands !facilities/ Common Areas" shall have the meaning ascribed
to it in Clause 7.4 of this Agreement;
{lii) "Total Lands" shall have the meaning ascribed to it m Recital A to this
Agreement;
I
Limited
"
Ad,on ' ' " " ' " ' " ' " ' Lfo•i<,d
Ornamct lat Rea hors
Prhatc Limited
Aspirant l~uilder;
Pdv,,te Ltitcd
llTVS
Limited
.,.l,11 '""''
Bulls lkalJm; Private
Limited i
Fiverivers Devl (}pen, Priv:ttc Com man .I-er Rea!tors

Limited 1 Priv:ite Ltiited
&
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339
16
([iii) "Total Project I<'Sl'' shall mean the total FSI available for the Project., which is
1197268 square feet (equ.i.valent to 111230 square meters) as represented by
IREO;
1
(!iv) •WDL's BUA" shall have the meaning assigned to it in clause 4. ! below.
(Iv) "WDl./'s Costs" shall mean any and all costs, charges, stamp duti.cs, fees,
expenses or payments of any nature or descriptron whatsoever, towards the
following -
(u) All costs and expenses to be incurred towards \VOL-Subject Lands

Development Obligations and WDL Obligations under this Agreement.
(b) Towards compliance ofobligations in terms of Clause: 3.14. ! and 3. l .'i of

this Agreement with respect to Subject Lands-EWS Units and Schools;
(!vi) "WDL GPA" shall have the meaning ascribed to it in clause 3. l l of this
Agreement herein;
(!vii) ''WDL Obligations" shall mean the following;
(a) WDL-Subject Lands Development Obligatkm:s;
(b) To incur all WDL's Costs;
(c) Not to do any act of omission or commission (in contravention with this
Agreement) in relation to the Subject Lands that would p,~juclice the
development en· construction of the Prezject•Su?ject l .,.i:mis , decrease the
FSI-Remaining Lands or Density-Remait. .,g Lands or would have an
effect of withholding or dcnying permission to occupy the \VD L's BUA,
IREO's BUA or the buildings/built-up area that may be constrnctcd on
the Remaining I ,ands;
(d) To construct and develop Subjecl LamJs-E\\•S Untts anJ Schools in

accordance with Clause 3.14.1 and 3. l 5 below.,
(e) To provide reasonable assistance to JREO in obtaining all Approvals,

sanctions and permissions, and rene,va!s extensions thereo( as may be
requested by IREO;
(t) To obser:tl laws, regulations and ril1catlons dca11ng ,,th all the
Wat~onia D~pcrs Private Orn amen!! R.:altors IHVS J:luil'.t)wclf l'nvatc

Irco PrivalLimited Limited ~ l'rivn!c Ltit('.,i Limited i
Base Expo js Pri.vate Aspirant ~tuihkrn Bulls Rt,a!Jirn Privnhi
Limikd Adson Softwar . Private Limited Privak Limited Limited '
Hverivers) wnship Finrivers De\ lopcrs Private Comman).r Realtc,rs

Private Umtted Limited i Private u!ited
&
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340
17
workers engaged frw the WDL-Subject Lands Development Obligations,

including payment of their dues, wages, gratuity, cess, taxes, benefits,
claims, working conditions, safety, accidents, complaints, litigation in
respect thcreoJ;;
(g) To observe and shall be responsible and liab!e for all customers/
allottees of any units/area in the Project-Su~jecl Lands and all
complaint<;, cfoir:1s, litigation made/initiated by them wlth rr~spcct to
WDL'sl3UA;
(h) To be responsible and !iable !or all contractors, architects, consultants,

technicians, engbecrs, persons (including its own employees}, brokers,
advertisers, engaged for WDL-Subjcct Lands Development Obligations
and or \VDL's BUA including payment of their bills, dues., salaries,
fees, taxes, benefits, claims, safety, accidents, complaints, litigation in
respect thereof;
(i) To maintain the Project-Subject Lands including the Subjt\ct Lands

Facilities / Common Areas till hand over of the same to the association
ofapartment owners as per Applicable Law;
(j) To enter into and exercise control over tl1e Suqject Lands for the
purposes of implementing WDL Rights and undertaking WDL
Obligations;
(k) Not to c(msumc FSl in eKccss of FS l-Su\::iect Lands or density in excess

of Density-Subject Lands over the Su~ject Lands under any
circumstances;
{l) To mrange construction finance for the implementation of the vVDL-

Subject Lands Development Obligations, in the manner it deems fit;
(m) To comply with all the conditions contained in the Approvals as may be
obtained from time lo time in relation to the implementation of the WDL
Rights:
([viii) "WOL Rights" shaH rcl.i:r to the rights, powers, enftternents, authorities thal
WfJL would have to undertake its obligations and duties, as specified in this
Agreement, with regard to WDL-Subjcct Lands Development Obligations and
WDL Obligations and shall also include (but not be limited to), inter alia, the
following:
'
J'
~/
'2~
Watsonia Developers 1'riva1e Oco,mrnJRe, It•~ i
1nvs B11i1'l1well Pri\atc
lreo Pnva~ Limited Limited Pdvatc Limited Limited
!.
Buse Expo \ s Private n\ Aspirant J\lder.>1
1
Limited Adson S<>ftwnrc ~rivn~ Limited Private Limited
Fh1crivcrs Lownship Fin:rivcrs Dcvdn\·er'/ l'rivatc Commandl Realtor~

Private. Li1~ ited Limited l'1·h /lie LiJ\ted
&
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341
l8
(a) To enter into and exercise such contTol over the Subject Lands, as is
required for implementing the WDL Rights and undertaking WDL
Obligations.
(b) To plan, conceptualize and design the entire Project-SLtbject Lands;
(c) To carry out the constrnction / development of the WDL-Subject Lands

Development Obligations;
(d) To appoint, employ or engage architects, surveyors, engineers,

contractors, sub-contractors, !abollr, workmen, per:sonnel (skilled and
unskilled) or other persons to carry out ~he WDL-Subject Lands
Development Obligations and to pay the wage::, remuneration and salary
of such persons;
(c) To exercise foll, free, uninterrupted and excl1;,sive sale rights in respect
of the WDL's BUA in accordance with Clause 4.3 herein;
(J) To make payment and/or receive the rcfond of all deposits, or other
charges, fees to and from all public or Government Authorities or public
or private utilities;
(g) To calculate th;;: Saleable .Arca of the entire Project-Subject Lands;
(h) To exercise !.bll, free, unintemipted, ex.elusive and irrevocable

rnarketing. !easing, licensing or sale rights in respect of the \VDL's BUA
by way of sale, lease, license or any other manner ortranster or crcmivn
of third-party rights therein, have exclusive t:ontrol with respect to the
pricing ofWDL's BUA and to retain all amounts thereof for itself;
(i) To make applications to the concerned Government Authority or semi-

governmental authority in respect of Approvals including environment,
levelling, water storage facilities, water mains, sewer~ge, storm water
drains, recreation garden, boundary walls, electrical sub-stations, water
and electricity connections and approvals for cement, steel and other
building materials, if any, w, WDL may deem fit, in the event IREO fails
to apply for the same within such time as is considered reasonable by
WDL;
To de.:il with, appear before and file ;lpp!icalions, declarations,

certificates and submit/ receive information witb, as may be n,"l.1uired
,mder tll°J.pplicable Law, any Gov rnment <\uthority as may be I
Watsoni:i Dcvcldpcrs Private Ornament ' BTVS Jildwdl Private
Limited Private Li Limited'
~I!/ i
Aspimnt Bi 1ifders
11
Bulls R~ltor:, Pri\,atc
Adson Snftwah Pdvatc Li111ited Private Li ited Limited,
Piverivers nJclopers .Private

Limited i
Com man lr Realtors
l'riYate Ltitcd
&
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342
!9
necessary for the development at the Subject Lands, in the event JREO
fails to apply for the same within sucb time as is considered rcasonabk
byWDL;
(k) To carry out and comply with all the conditions contained m th('
Approvals as may be obtained from time to time in relation to the
Project-Subject Lands;
(l) To create m<)rtguge / hypothecation ! charge on the Subject Lands /

receivable from entire development being part of the Project-Subject
Lands or any part thereof for raising construction finance for the Project-
Sul~jcct Lands;
(m) To sell, transfer, assign all benefits., rights and obligations as contained
herein (in wh()le or in part) including 'N1)L 's BUA tn any third party, at
its cost, risk and expense and to retain all amounts thereof for itself~
provided always the benefos, rights and obligations as contained herein
can be assigned by WDL only to an Affiliate and the WDL's BUA can
be sold/ transforred to any third party;
(n) To launch the Project-Subject Lands Jor sale of WDL's BUA;
(o) To execute all necessary, legal and statutory writings, agreements and
documentations for the exercise of \VOL-Subject Lands Devdoprnenr
Obligations, \VDL Obligations a11d in connection with all the marketing
and sale of WDL's BUA, and require IREO and the I,and Owners to do
the same;
(p) To manage the Subject Lands and the property and facilities f common
areas constructed upon the Subject Lands as may be required under the
Baryana Apartment Ownership Act, (983 or any other Applicable La'NS
and/or rules made there under and / or to transfor/ assign right in
maintenance to any third and to collect and retain aH benefits, charges,
fees, security deposits, amounts from the allottees ! purchaser of the
entire Saleable Area of the Project-Subject Lands;
(q) To consume FSI and density over the Subject Lands up-to the FSl-
Subjcct Lands and tbc Density-Subject Lands;
(r) In the event of default by fREO in compliance of its obligattons under

this Agreement, at the sole discretion of WDL to do all SLiCh nets, deeds
and things ~at may be required for thejProjed~Subject Lan<l I Project
1
~ II Iii
,:vatsonia Ih:;.~p1,m; Private Ormiment;~ Realtors BTYS lluilJwcll l'rivak
Limited ft. ·
P n-vate ,rite
1
I' ' d ' ' I
[,,1m1te(
~/ Aspirant j~ui!der~ Reai!rs Private

flulfs
Ads(m Softwa1'1e Privak Limited l'l'ivnte L\hlited Limited [
'I
Fivcriver~ 1\,wnship
Private Limited
Fiverivers lkJlopcrs Private:
Limited \
Comman tr Rcllltcrs
Private Ltited
&
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343
20
or for compliance of the terms in this Agreement including obtaining the

building plan approvals, other Approvals required in respect of the
Project-Su~jcct Lands/ Prt~ect, and/ or modification in connection with
the zonal pian, layout plans, architectural plans or any Nher Approvals,
apply for and obtain the completion certiftcatt~ and occupation certificate
and performing all acts towards the same in rcspcc:-t of the Project-
Subject Lands or any part thcrcot;
(s) To do aU such ;;icts, deeds and things that may be required FJr ttw
Project-Subject Lands / Project or for compliance of the terms in this
Agreement including, if necessary, obtaining the building plan
approvals, other Approvals required in n.::,pe"'t of the Pn:,'.ject-Subject
Lands / Project, and/ or modification in connection with the zonal pbn,
layout plans, architectural plans or any other Approvals, apply for and
obtain the completion certificate and occupation certificate and
pertorming all acts towards the same in respect of the Project-Subject
Lands or any part thereof, in the manner as set out in thi::; Agi:ecmcnt;
(t) To take appropriate actions, steps and seek compliances, approvals and
exemptions under the provisions of the Applicable L<tw, and
(u) To generally do any and all other acts, deeds and things that may be
required for the exercise of the WDL-Subject Lands Devck1pment
Obligations, WDL Obligations and as more elaborately stated in this
Agreement, and undertake all such acts, deeds and things in respect of
the Project-Subject Lands that may not have been specilically dealt with
in this A&,rreement
(lix) ''\VOL-Subject Lands Development Obligations" shaf! be as provided in

clause 3.16 and Schcdule.V herein.
(Ix) "Zonal Plan'' shall mean and refer to the zonal plan currently sanctioned by
DTCP in respect of the Project
1,2. Interpretation
L2, 1 ln this Agreement, unless the contrary intention appeiirs any rcfcrenc~; to any statut0 or
statutory provh;ion shall include:
(i) all subordinate legislation made from time to time under that statLH) or statutory
provision (vvhether or not amended, modified, re-enacted or consolidated);
\
c~,·
,1
{,,/
/
Irco .l'rfratclLim itc<l
W.ts,oia
Limited
»i°;rt "'"" Om,m'""'
Private Limited
1""~ IH'S ••
Limited
L,., "'' ""
Ibse Expor s Priva re
~
A~pirant U1fildc~
,!
Bulls Retllors Privak
Un1ite,! / Private Liniited Limitd.
i 1\
!1
Fiverivers -~()Woship Fi"erivers Devel½1n:rs Private Comrnandlr Realtor~
Private Limlted Limited \ Pril'ate Lit1ited
&
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344
21
(ii) such prov1s10n as from time to time amended, rn.odificd, re-enacted or

consolidated (whether before or after the date of this Agreement) to the cxt<;,nt
such amendment, modification, re-enactment or consolidation applies or is
capable of applying to any transactions entered into under this AgreemenL and (to
the extent liability thereunder may exist or can arise) shall include any past
statutory provision (as from time to time amended, modified, re-enacted or
consolidated) which the provision reforred to has directly or indirectly replaced;
(iii) any reference to the singular shall include the plural and vice-ve.rsa;
(iv) any references to the masculine, tbe feminine and the neuter :;;hall include each
other;
(v) any references to a "company" shaH include a reference to a body corporate;
(vi) any reference herein to any Clause or Schedule or Annexure is to such Clause of
or Schedule to or Annexure to this /\grecment. The Schedules and Annexures to
this Agreement shall form an integral part of this Agreernent;
(vii) references to this Agreement or any other document shall be constrncd as

reforences to this Agreement or that other document as nmen(k:d, varied. novClted,
supplemented or replaced from time to time;
(viii) the expression ''this Clause" shall, unless followed by reference to a specific
provision, be deemed to refer t() the entire section (not merely the sub section,
paragraph or other provision) in which the expression occurs;
(ix) each of the representations and warranties providec\ in this Agreement is

independent of other representations and warranties ard unless the contrary is
expressly stated, no Clause in this Agreement limits the extent or application of
another Clause or any part thereof:
(x) any reference to books, files, records or other information or any of tb,~m means
books, files, records or other information or any of :hem in any form or in
whatever medium held including p,tpcr, electronically stored data, magnetic
medfa, film and microfilm;
headings to Clauses, parts and paragraphs of Scbeduks and Sche<luks are for
convenience only and do not affect the interpretation of this Agreement;
(xii) "in \,Vriting" include, any cumrmmication made by letter, fax or e~mail;
r l
i
'41) ~I
i ii
111'
Watsonia Develope1·s Private Ornamenta, ~ciiltor~ BTVS Bu~,1lwcll l'rivate

lreo Privatetimited Limited ~ l'rivat<.> Limited Limitecl
Base Expori l'riYate j ,c,p;~" t;tdm B,U, R<01orn r,;.,"

Limited ,: Aih~m S<iftwHc~Privak Limited l'rivatt! Um;ted Umite:d '
I
I
l
Five.rivers. T ,nship
.Private t.imifd
Fh1erivers Devlopel's Private
Limited u\
Cornman)\ Realtors
Private LiJf;ted
&
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345
22
(xiii) the words "include", "irictuding" and "in particular'' shall be construed as being
by way of illustration or emphasis only and shall not be constrm::d as, nor shall
they take effect as, limiting the generality of any preceding words;
(xiv) reforences to a person (or to a word importing a person) shall be construed so as

to include:
(a) individual, firm, partnership, trnst, joint venture, company, C{)rporntion,

body corporate, unincorporated body, association, organization, any
government, or state or any agency of a government or state, or any local or
municipal authority or other governmental body (whether or not in em.:h
case having separate legal personality);
(b) references to a person's representatives shall be to its officers, employees,

legal or other professional advisers, sub-contractors, agents, attorneys and
other duly authorized reprcsentmives;
(xv) where a wider construction is possible, the words "other" and "otherwise" shall
not be construed ejusdem generis with any foregoing words;
(xvi) all the recitals to this Agreement shall form an integral and operative part of this
Agreement as if the same were set out and incorporated verbmim in the ,>perativc
part and to be interpreted, construed and read accordingly.
1>EVELOPMENT OF PROJECT~ SUBJECT LANDS
2.1 On and from the Eftective Date, tREO and the Land Owners, grants and transfers in
favour of WDL, the WDL Rights in respect of the Sul~jcct I ands/ the Project-Subject
Lands.
2.2 The Project~Sul>jcct Lands shall be developed as a single project, by \VDL and lREO
undertaking their respective, separate and specific ob!ig::itions ln the Proj::ct-Subjcct
Lands, in the manner set out in this Agreement
23 The Prnject-Subject Lands shall be developed by WDL and !REO by implementing the
WDL-Su~ject Lands Development Obligations and lRI.J)-Sul*ct I,ands Development
Obligations, respectively.
2.4 WDL shall be entitled to implement and utilise the \VDL Rights and lREO shall be
entit!.ed to implement and utilise the lREO Rights, in au:ordancc with the t•:rms of this
Agreement
'
4,v
Irco Private Limited
Om""""'.l,IM"
Private Limited
I
HTVS Uuitwd! Priv1.1tc
Umited i
Limited
[!
Base Exportf l'rivatr
\
Adson Software: ~rk·atc Limited
d
r>rivate '
Aspirant Iti1<krs
Limited Limited i
I
Bnl!s Rea(wn Private
Fiv.ir'ive!'$ Tivnship f'ivcrivcrs Devl>pers Private CommandJl Reu.ltQrs

Private l,i,nittd Limited l' Private Limited
&
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346
23
2,5 WDL is folly authorised to enter upon the Subject Lands directly or through its
Afriliates, associates, nominees, agents, architects, consultants, representatives,
contractors, and/ or subsidiary, to do all such acts and deeds r~quired and/or necessary
for, exercising the WDL Rights and/Qr for the implementation Qf the WDL-Subject
Lands Development Obligations on the Subject Lands.
2.6 The Parties agree that 740000 square foct (equivalent to 68748 square meter) of the FSl
("FSI-Sub,icct Lands") and Density-Subject Lands shall be utilised on the Subject
Lands out of the Total Project FSI and Density-Project Lands as part of the Project-
Subject Lands. ft is understood that the total construction area in the ProjecL-Subject
Lands will he at-least. 100000 square meters (equivalent to 1076390 squart feet) in
complianc,: witb Applicable Law. IREO and WDL wilt undertake IREO-Subject Lands
Development Obligations and WDL-Subject Lands Development Obligations,
respectively, in accordance w.ith Schedule-\!.
It is agreed and understood tNtwcen the Parties that WDL has entered into this
Agreement on the representation of IREO that the FSI-Subjcct Lands is permitted to be
developed on the Subject Lands, and the same shall be utilised as part of the Project~
Stibject Lands. In the evem of any reduction in the FSI available to the Total LanJs /
Subject Lands / Remaining Lands, the FSI-Remain1ng Lands would reduce, without
any impact on the FSl-Subject Lands that is to be utili::;ed on the Subject Lrinds.
Simi lady, in the event of any enhancement ln the FSI under the Licence, the enhanced
FSI would be added to the FSI-Rcmaining Lands entitling fREO to develop the same
on the Remaining Lands as part of the Project-Remaining Lands or otherwise at any
other locution as deemed fit by IREO. In ca,;e of any alteration of the FSI-Remaining
Lands as provided in this clause. IREO sha)] inform WDL in writing within 3 (three)
days of such alteration. However, it is agreed that in the event of an increase in the
Density as currently permitted under the Zoning Plan from 300 Persons Per Acre, the
same shall be prnportionaiely divided between Project-Subject Lands and Project-
Remaining Lantis in the prnportion of current Density-Subject I,ands and Density-
Remaining L,mds. It being clarified that any increase in Dc11si,y-Pmject Lands only
attdbutable to the increase in FSI under the Licence shall be S(}le[y to the account and
benefit oflREO.
3. IMPLEMENTATION OF THt:: PRO.J.ECT-SUB.JECT LANDS
3.1 IREO undertakes full responsibility and obligations to comply with lREO Obligations
including fREO-Subject Lands Development Obligations and incur all IREO's Costs.
IREO undertakes to comply with IREO~Subject Lands Development Obliga::ions in a
timely manner.
3,2 J;twithstanding the lREJ) Rights, the !andscapil1g, conccptuaHzatioN, planning,
v
' . /f,\ '
Watsonm Developers Private
I\
Orname,it Rcultoni
M
1rrvs !ti!dwell Private
lrco l'rivat Limited
1 l.imite<l Private timited Limited
Base Expo
Limited
~~
~
f'rivatc ti
l
Adson Sof!,,,ue Private Limited
A,p;~,~"itfo,
l'riv:1te liimited
h•II>
Limite~
ji.,tac, P,;,,,,
I
Fivei-ivers ) wnship
Private Lim~ed 1
Fivcrivers .(veloper5 Private
Limited
Cim1man£cr Realt,n·s
Priva,c Li,nited
&
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347
24
architecture, construction and design of the i:ntire Project-Subject },ands shall be al. the
sole discretion and expertise of WDL, without any recourse to or interference from
!RBO and / or the Land Owners. The dctaili.ng, master planning, zoning, lay out, etc.
and al! other details and specification for development of the entire Project-Subject
Lands on the Subject Lands shall also be done by WDL.
3.3 WDL shall be entitled to appoint, employ or engage architects, surveyors, engineers,
contractors, sub-contractors, labour, workmen, personnel {skllled and unskilled) or
other persons to carry out the development work torming part of WDL Rights and to
pay the wages, remuneration and salary of such persons.
3.4 WDL undettakes full responsibility and obligations to comply with WDL-Subject
Lands Development Obligations in timely manner and incur all \VDL's Costs, Further,
it is clearly agreed and understood that towards. compliance of WDL-Subject Lands
Development Obligations, and to ensure harmonious development of the Project, WDL
shall only employ reputed contractors, architects, surveyors aM engineers, and enter
.into conlracts with them, as is standard industry practice.
3.5 It is clearl.y agreed and understood that towards compliance of lREO-Subjcct Lands
Developrrwnt Obl.igations, and to ensure harmonious development of the Proje:;d-
Subject Lands, lREO shalt only employ constrnction contractors, architects, surveyors.
consultants, technicians, engineers and 11!! other service pn.~viders out of a list of such
contractors, architects, surveyors, consultants, engineers ai1d service providers that sha!l
be used by WDL for WDL-Subject Lands Development Obligations or that may be
suggested by WDL to IREO. Further, to ensure harmonious and smooth development
of the Prqiect.-Subjcct Lands, rhe contracts / agn:ements / arrangements, work orders
and instructions that are entered with / issued to such contrnctors, architects, surveyors
and engineers by IRE() from time to time sball n:quire to be appr(}vcd by WDL.. WDL
shall be en!itk:d to suggest modifications/changes to the contracts/work order~ in
consonance with the landscaping, conceptualization, planning, architecture,
constrnction and design of the entire Project-Subject Lands prepared in accordance
with clause 3.2 above and as may be revised from time to time by WDL. fREO further
undertakes to employ contractors, architect5, surveyors, consultants, technicians,
engineers and all other service providers for the JREO-Subject Lands Development
Obligations and complete the development/ construction within such time as is detailed
in the GonceptuaJization & planning for the Project-Subject Lands prepared in
accordance witb Clause 3.2 herein.
3.6 WDL shall be entitled at its sole discretion to appoint/ nominate any of its At1iliates as
a project manager I development manager to undertake the dcvdopment and
construction of the Project-Su~ject Lands and all obligations, rights and entitlements of
1.~ under this Agrecnwnt, and to trnnsfer / <9sign all such entit!', ment::; and
L . /'Pn Ii\ /11.
Watsonia Developers Private OrnamenJ}il Re!!ltor.1 IHVS B, 1ildwell Priva1e
lreo l'riv111, Limited Limited Private yfmitccl Limited:
'Base Expo' ts Pl'irntc \, A,pinrnt~Builders Bulls Jealtors Private

Limit~d Adson Softwhe ~nvatc Limited Private Limited Limite,l
t
.Fiverivers 'ownsbip
l"rlvate l,h,ited Limited ~
Fivcriver, Dtdopers PrivMc Comm.u~cr Realtors
Private nimitctf
&
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348
2S
obligations in favour of the said Affiliate as may be deemed appropriate by WDL. No

approval or consent shall be required in this regard from IREO and / or the Land
Owners.
3. 7 Approvals -
3. 7. l Revenue Rasta: A Revenue Rasta of 11 feet width and a total a.rea of 18 Marla<: (0. t 125
acres) demarcated in blue colour in the plan attached as Schedule-III traverses through
the Subject Lands. IREO shall make its best efforts to get the Revenue Rasta shifted
from its current position such that no Revenue Rasta tr:;ivcrses through the Subjed
Lands. As part of its best efforts, IREO has represented that the resolution from
Panchayat and recommendation from BDPO has already been obtained for exchange of
the lands under the Revenue Rasta with an alternate rasta/road as n1arked in red in the
plan, which is Schedule-III. 1he said alternate lands/ rasta/ road mny consume certain
lands out of the Subject Lands, at its boundary, as demarcated in orange cok,ur on the
plan, which is Schedule-UL In the event the said Revenue Rasta is shifted, the land
under exi~ting Revenue Rasta shall be deemed to be added to the Subject Lands for th¢
development of the Project- Subject Lands,
3.7.2 Zoning Plan Approval: The Zonal Plan for the Project Lands is already approved.
Further it is agreed and understood that in the event the Additional Lands or Part
Additional Lands are added to the Licence upon certain part of the Remaining Lands
being taken out from the Licence in terms of Clause 8.1, 8.2 & 8.3 herein below, the
zoning plan approval for the revised Project Lands will be obtained by m.EO within the
timclines provided in Clause 8.1, 8.2 & 8.3 herein.
3.7.3 /U212IQ.Yal.s for the Project. Project-Subiect Lands and Proi~9t~R~JJJ;;1in,ing_J,an~t~: All
Approvals and their renewal / extension / modificatkrn that may be required to be
obtained for development, construction, occupation and completion of the Project,
Project-Subject Lands and Project-Remaining Lands shall be the responsibility ofIREO
at all times. The cost, expenses, duties and fee relating to all Approvals shall be borne
by IREO. lREO shall be responsibie to prepare all applications, undertakings,
affidavits; plans etc. that may be required towards obtainment of such Approvals. h is
agreed and understood that all applications, undertakings, affidavits, plans etc. that arc
required to be submitted to Government Authorities for Approvals which are specific to
the Project~Subject Lands or that may be common to the entiri; Project, will require also
being approved by WDL. IREO shall provide a complete set of all such app1ications,
undertakings, aflidavits and plans to \VDL for review. All modifications, suggestions.
alterations and additions that WDL may require in such applications, undertakings,
affidavits, p!ans etc. shall be duly incorporated before the same arc submitted to I filed
with the Government Authorities. IREO shall obtain all Approvals and/ or any renewal
/\extension/ modification in respect of the same withinfuch timelines as ii; considered
lr,:o
qy
Privat~l. imitctl w,m,,i, ~P'" '''""
1..imrt~d
1
Om,m"~&"'"'"
Private t;mitcd
81'~ Htdw,11 Prin«
LimiteJdf
Base Expor( Private I Aspirant~uild<.!rs Hulh l ,tlt{)rs l'rivllh:

Umitecl , {l.
I
Fiv<::dve .-s Tow1,(l.1,ip
Private Limited ~ l.imited
. t
Adson Softwaretl'ivate Limited
fiiv,irivers Developers• ivate

,
Private rl~ited
Commim·lr Realtors
Private Lf ited
Limited
&
TRUE COPY
349
26
reasonable by WDL and / or within such time!ines as are devised along with the
landscaping, c<.mccptualizntion, planning, architectme, construction & design of the
Project-Su~iect Lands prepared in accordance with Clause 3.2 above und as may be
revised by WDL from time to time,
3, 7 A Uuildipg Plans for the Project-Remaining Laqgs: lt is also agreed and under~tood thttt
priot to submitting the building plans by lREO in respect of the Project-Remaining
Lands, a copy thereof shall be furnished by IREO to WDL for review by WDL. WDL
shall be entitled to review the building plans for Remaining Lands to veri~y the area
statement therein and to ensure that the prop()scd built-up area on the Remaining Lands
does not atfoct the FSI-Subject Lands and /or the Density-Subject Lands, and / or the
requirem.enl of E\VS Units or schools/nursery schools in the Project- Subj,;t:t Land:;.
\VOL shall be required to respond to IREO within a period of fifteen (15) Business
Days vvllh its objection l confirmation, as the case may be from receiving a complete
set of the building plans from IREO. [n the event WDL fails to respond within the said
period of fifteen (15) days, IREO shall be free to proceed with submissions of such
draft building plans to tbe Govemment Authorities for approval.
3,75 LiCSJl§~ - The License in terms of the Renewal Memo is valid up to January' 20 l 4,
IRBO shall obtain renewal of the License on or before January' 20 l 4 for further periods
till January' 2016. ft being understood between the Parties that renewal or the Licence
will be applied at-least 30 days i.n advance to the expiry of the Licence ,md normally
tit;; renewal of the Licence is granted by DTCP within 6 (slx) months of the date of
expiry. All subsequent renewal Le. after January' 2016 shall be obtaim:d by lRFO,
provided constnwtion of the Project-Subject Lands hus commenced in right earnest
before January' 2016, if the same is required for renewal of Licence beyond January'
2016, as per DTCP, Subject to commencement of constructfon as above, IREO shall
ensure that the License is valid, subsisting and is in foll force and effect till the time the
entire rights and obligations of WDL under this Agreement, including the WDL Rights
are utilized and implemented to the satisfaction ofWDL The cost, expenses. duties and
foe relating to renewal of License:: shall. at all limes be borne by IRF:O.
3.S lREO and Land Owners shall extend all cooperation and do aH such acts and deeds,
that may b,;; required to give, effect to the provisions of this Agreement, including,
providing all such assistance to WDL, as may be required by WDL from time to tirnt;
for the purpose of carrying out the transactions contemplat.c,cl hcr~by. IREO and Land
Owners further agrees to_, and shall execute, as may be required by \,VDL or otherwise,
from time to time, all applications, affidavits. plans or other documents, and shall also
extend all cooperation and assistance for the development and completion or th\;
Project-Subject Lands and marketing/ allotment/ sale! transfer of the WDL's BUA
~ n,ay request forlti purpose of carrying OJ~t tl,e tr,m,;;ctions 'f

IREO shall ftirnish all such relevant information in respect of the Projec:l Lands, a:,;
temp lated
r,/ ,vatsonia De~lopers Private Ornumen ,I Rtaltor,, !HYS Bui~dwcll l'rh11t~

Ireo l'drnt, Limited Limited Private Li ·ited Limited '
I>
,.isc, : lDi,·
.:xp~f~~ : nvatc l
1' J
Aspirant l~uilders 1\
Bull~ Rc:~tors Private
Limitrd '' Ad~rm Softi ..ire Private Limited Private Lilltitcd Limited '
\ I
Fiv.:rivcrs ·t~1wnshlp Fi\.'UiYcrs D!yc!(1pcrs l'rh•atc Comm11nlfor Realtors

Pt·ivatt Lin1ted Umitctl Private I. mitcd
&
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350
27
hereby. In the event WDL requires any assistance including execution of any
document, application, affidavit, power of attorneys, etc., IREO shall do so, subject to
C",,ompHance of legal requirements thereot: within 7 (seven) days of receiving the
request from WDL.
3.9 WDL shall extend all cooperation and do all such acts and deeds, as may be required by
IREO from time to tfme for the purpose of carrying out the IREO~Subjcct Lands
Development Obligations, within reasonable time of receiving request from !REO.
:uo The development / construction of the Project-Subject Land':l may be carried out in
phases and as per such timelines that are in accordance ,vit.h the conccptuali?lltion,
planning, architecture, construction and design of the Prqject~Subject Lands formulated
in accordance with Clause 3.2 above and a:, may be revised by WDL from time to time.
3. ! l Without prejudice to the obligations and entitlements of fREO, the Project Land
Ov.mers and Additional Lai1d Owners (in the event Additional Land is added as per
Clause 8 belmv), to do all deeds, acts and things as are required fbr to be done by them
in accordance with this Agreement, IREO, the Project Land Owners und Additional
Land Owners, agree and undertake, to execute in-evocable power of attorneys in the
agreed formats in favour of WDL or its representative in rn::;pcct of the entire Subject
Lands and Additional Lands, so as to enable WDL to perform WDL Obligations and
WDL Rights under this Agreement (all Power of Attorneys are coikctively reforred to
as Lhe "Wl)L GPA"). JREO, the Subject Land Owners and Additional Land Owners
(in the event Additional Lands is added as per clause 8 belo,.v) are fo!ly aware that
WDL has entered into thi::; Agreement relying upon their reprt:senta!ions that the WDL
GPA shall be maintained and not revoked till the completion of the Project-Subject
Lands and ti!J such time as WDL has undertaken and completed all \.VLD Obligatkms
and "\XlDL Rights. lREO, the Subject Land Owners and Additional Land Owners fully
understand and agree that in the absence or the WDL GPA, \VDL shall not be able to
perform WDL's entitlement to implement its obligations relating to the Project-Subject
Lands and to market and sci[ the WDL's BUA. Thus, IREO, the Project Land Owners
and Additional Land Owners agree and undertake not to caned, revoke or modify the
WDL GPA and to keep the same in f'uU force and effect till the completion of the
Project-Subject Lands and after that as rnay be required tor 'vVDL to uncknake and
complete all WDL Obligations and WDL Rights. The WDL GPA. shall be irrevm:ablc
and WDL shalt be entitled lo de.legate any or all of the po,vcrs and authorities under the
WDL GPA to any of its Affiliates, employees or represematves. WDL shall have an
unequivocal right of specific performance in the event of revocation / modification /
alteration or cancellation of the WDL GPA, prejudicial to WDL or otherwise along
with all injunctive remedies, as also provided in clause 17 herdn. The WDL GPA shall
be executed and registered, at the cost and expensclof WDL, simultaneously with the
~ecution and registration ~,Phis Agreement
\ £!"
I
/2~,
;;;l5i
,j""-
vVatsonia Developers Private
II
I
Qnrnmc~:111 Rcait<.>r,
\
,
BTVS ~11ildwell Private
lrco l'rtvute rrnited Limited . l'rivate Limited Limited
~
Base Expmii Private ~' . Aspiranl!Huiider~ Bulls ~calt,1r~ Private,
Limited Ads{m Sofl•:m: Priv:1tc Liniitcd Private IJimited Limite
l .
r1
Fiverivers ,ownship 1/iveriver~\bcvelopcr~ P.-ivate CommJ1del' Rea!ton;
Private Lilted Umitetf , l'l'i'v1,te ~,imitcrl
1
&
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351
28
3.12 lt being expressly agreed that in the event IREO fa.Us to di~chaxgc any of the lREO
Obligations, including its obligations with regard to obtaining the Approvals and / or
any renewal / extension in respect of tbe same within such timelines as is considered
reasonable by WDL and / or within such timelines as are devised along with the
landscaping, conceptualization, planning, architecture, construction & design of' the
Project-Subject Lands prepared in accordance with Clause 3.2 above, then
notwithstanding any other right or remedy available under this Agn:ement or
Applicable Law, WDL shall be entitled to take necessary steps for obtaining such
Approvals under the authorisation granted vide WDL-GPA, at the cost and <;xpense of
fREO. IREO shall reimburse such amounts to WDL forthwith upon re,;civing an
intimation of such expenditure from WDL. In the case of an;1 <leiay in such payments,
then notwithstanding any other right and remedy available to WDL under applict~ble
lavv, an interest @ I8% per annum shall be payable by lRE:0 to WDL for the entire
delay period.
3.13 To facilitate the construction and development of the Project-Sul~ject Lands on the
Subject Lands, WDL shall create equitable mortgage or any otber form of mortgage or
exclusive charge on the Subject Lands and /or all receivables under the Project-Subject
Lands in favour of th<: Lenders by depositing/actual and / or by way of constrnctive
delivery, the <)riginal title deeds and documents of the Subject Lands to raise
construction finance, as and when so required by WDL. Adequate authorisntions will
be provided to WDL in this regard under the WDL-GPA. Further, the Land Ovmers and
IREO agree and tmdertaki: to sign andi or execute all the ncci.:ssary do,:urncnts,
agreements, deeds, declaration, no-objection certificates etc. in favour of sud, Lender
and/or WDL, if required, forthwith on being requested by WDL. However, Land
Owners and IR.BO shall not provide any personal/corporate guarante() for such
financing.
3.14 Construction and development ofEWS Units:
3.14.l In accordance with the Zoning Plan, it is ro;;quired that l5'% of the total dwelling units
shall be of economically weaker sections of the society (''K\VS Units"). lt is ugrccd
betwee11 the Parties that 15% of the total dwelling units and shops of the Pr~jed-
Subject Lands will be EWS Units ("Subject Lands-EWS Units"), which will be
constructed by WDL on the Subject Lands, and similarly 15S·~ of the total dwelling
units of the Project-Remaining Lands and shops will be EWS Units ('"Remaining
Lands-EWS Units"), which will be constructed by lREO on the Remaining Lands.
Parties undertake to adhern to all the conditions as laid out in the Zoning Plan with
respect to the EWS Category, in respect to the number and size, with r~spect to the
.number of dwelling units under EWS Category to be built on the Sul::ject L<3:nds and the
R:l:ining Lands. ~ 'I
';{Y
w,.,.;,
Limit.id
tl:i.," r,;,o« orn,m,\.,, '""'"'' •rvs .t,,a,.,, r,;,.,,.
Private l\imit~d Limited '
Base Expm
Limited 1! l'rivatc ~
Adson Softwark Private Limited
Aspinmj Builder~
Private Limited
llutls R~ altors Private
Limit,j
\
Y.'ivcrivers He-.·~I-Opcrs Private CommJn(ler R~altor;
l,imit~d \ Privlltc ~-imitc•l
'
&
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352
29
3.14.2 WDL shall be entitled to locate the Subject Lands-EWS Units on the Subject Lands as
per its sole discretion. lREO shall not interfere in any manner in the construction of the
Subject Lands-EWS Units by WDL or raise any claim against WDL in this regard.
WDL shall be entitled to handover/ allot the Subject Lands-EWS Units and appropriate
the consideration (if any) received there from. If any Subject Lands~EWS Units arc not
acquired by the State Government or not to be compulsorily allotted to EWS category,
then WDL shall have the full authority to deal with the same as it may detm1 fit and
proper.
3.14.3 Similarly, IREO shall be entitled to locate the Remaining Lands-EWS Units on the
lands other than the Subject Lands i.e. the Remaining Lands and / or any other lands, as
deemed fit by TREO, subject to compliance with Applicable Laws. Accordingly, the
bullding plans to be prepared for the Remaining Lands to be prepared by lREO would
also show the Remaining Lands-EWS Units in the said plans.
3.14.4 Prior to any part of the Project-Subject Lands being completed and \VDL requiring
fREO to obtain the occupation certificate / part occupation certificate in respect thereof,
IREO shall complete all such construction in the Remaining Lands including the
Remaining Lands-EWS Units and schools, as may be required/ essential/ pre.. requisite
for grant of part occupation certificate / occupation certificate for any construction
completed on the Subject f ,ands as part of the Project-Subject Lands. ft is agreed and
acknowiedged by lREO that completion of such co:istructfon by !REO is an essential
covenant of this Agreement. !REO agrees that WDL will suffer immediate, material,
immeasurable, continuing and irreparable damage and harm in tht~ event of any delay in
completion of such construction on the Remaining Lands as may be required to obtain
the occupation cetti ficatc / part occupation ..,,erti fkate in respect of any construction
activity completed by WDL us pM of the Project-Subject Lands. lREO undertakes to
keep WTIL indemnified in this regard.
3.15 Schoo ls:
{a) In the event the Additional Lands arc not added within the tlmelines provided in
Clause S. !, all schools to be provided in the entire Project, sha!l be provided by
IREO in Remaining Lands as part of the Project-Remaining Lands.
The understanding in this Clause 3.15 (a) will not alter if the Part Additional Lands
are added at any stage to the Subject Lands in accordance with Clause 8.3 below
i.e, if only Part Additi<mat L,mds are added to the Subject Lands, a!l schools to be
provided in the entire Project, shall be provided by IREO in Remaining Lands as
part of the Pn.zjcct-Rcmaining Lands.
I~
,,.✓~;
-... ·,
/4~ ~
Del;opers
111
,..,/•"
lreo l'riv.al Limited
Watsonia
Limited •
Private
I'
Ornamental Realtors
Private Limited
BTVS Blwell '"""
Limited i
11
i
Base Expo+s Private
Limite\t Adson Softwale Private Limited
Aspiraltt B11{ldcrs
Private Limited Limited t
Bulls Rea f\ns Private
:1
l.
Fiverfvers owns hip l'iverivcrs DevJLpers l'dvate Commande iRea!tor,~
Private Ll~ited Limited ff l'rivak Limied
&
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353
30
{b) 1n the event the Additional Lands are added in accordance with Clause 8. l herein
and within the timelincs provided therein, and only one mm;ery school is to be
provided in the entire Prqject, the same shall be provided by WDL as part of the
Project-Subje(,'t Lands to be developed on the aggregate of the Subject Lands and
the Additional Lands. It is clarified that in the event the one school that is to be
provided is not a nursery school, the same shall be providt~d by IREO on the
Remaining Lands as a part of the Project-Remaining Lands.
(c) In the event the AdditJonal Lands arc added in accordance with Clause 8. l herein
and within the timelines provided therein, and more than one school is to be
provided in the entire Project; the nursery school shall be provided by WDL as part
of the Pr~ject-Subject Lands to be developed on the aggregate of the Subject
Lands and the Additional Lands. All other school(s) I the primary 8Chool (s) shall
be provided by lREO on the Remaining Lands as part of th,; Project-Remaining
Lands.
3. l6 The lREO-Subjcct Lands Development Obligations and WDL-Subject Lands

Development Obligations shaH be as set out in Schedulc-V. Tht: obligations may be
further defined / demarcated in accordance with Schedule-V upon sanction of the
building plans prepared by \VDL for the Pr~ject-Subject Lands, by WDL However,
the same shat! be in lines of the parameters provided in Scbcdule-V.
4. AREA ENTITLEMENT -
4.1 In consideratio11 of the respective obligations that lREO and WDL shall undertake nn
the Prqject-Subject Lands, the Saleable Area in the Project-Subject Lands shall be
reserved as follows•
(i) 25 % of the residential Saleable Area (calculated in square feet) in the Project-
Sul::ject Lands shall be reserved for IREO, along with proportionate car parking
space ("UlEO's BUA''). IREO's BUA shall be demarcated in accordance with
Clause 4.2 below.
(ii) 75 % of the residential Saleable. Area (calculated in square foet) in the Project-
Sul-::iect Lands shall be reserved for WDL, along with proportionate car parking
space (''Wl)Vs BUA"). WDL's BUA shall be demarcated in accordance with
Clause 4,2 below. If tbc Project-Subject Lands comprise of any saleable area
other than re:,.;idential construction, such as commercial spaces, then such
saleable area shall be reserved for WDL as part of WDL's BUA and WDL shall
be entitled to all receivables from the same.
~
lre,11'rivn1e fimittd
Watsonia Devcl\lptr~ Private
Limited
Ii
Ornamentn~Realtors
Prirnte Li~lited
BTVS
Limited
Ldw<II I'm>"
I
Base Expor~ Private
Limited ·n A<lson Softwte l'rivim• Limited
i
A~pirant ll ildcr<
Private Lin 'tcd
i
Bulls ultws Private
Limite~
fiveriversT.(Lnship
l'rh·itte LimiJd
'
Fiverlver$ J)eveivpen, Private
Limited l
Cornman l~
l'rh·ate L$i,ited
Realt11rs
&
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354
3l
4.2 It is agreed and understood that WDL's BUA and lREO's BUA shall be demmcated on
the final Building Plans approved by WDL in respect of the Project-Subject Lands.
within 30 (thirty) days of sanction of the said Building Plans in respect of the Project-
Subject Lands. It is further agreed that such demarcation and aHocation shall be carried
out by WDL, in consultation with IREO. The Patties will record the understanding in
an agreed format.
4.3 Each Party shall bt: free to dispose, sell, transfer or otherwise deal with the built-up
areas as mentioned above, and enter into agreements with the prospective purchasers
(as attorneys of the Land Owners), and receive and appropriate the full and complete
proceeds as per the agreed terms and give receipts and hand over ownership and
possession of the saleable areas (as attorneys of the Land Owners) of the Project-
Subject Lands falling to their respective shares to the purchasers/ allottees,
4.4 WDL shall be entitled to collect and appropriate EDC, IDC wd all other charges from
the purchasers I allottees of apartments forming part of WDL 's BUA that it may deem
appropriate. It is clarified that notwithstanding that the EDC and the roe charges for
the entire Pn~jcct \Vilt be paid by fREO to the Government Authorities, WDL shall be
entitled to receive, collect and appropriate the EDC and IDC charges that are collected
from the allonecs / purchasers of saleable area in WDL's BUA us part of the basic sale
price and/or separately. Similarly, IREO shaH be entitled to collect and appropriate the
EDC and JDC charges that are collected for IREO's BUA. Further, all charges or
d,,posits towards maintenance of Project~SuqJect Lands shall be appropriated and
utilized by WDL in the manner it may deem fit in respect of the Pr(*ct-Subject Land:-;.
5. RlI:FUNDABLE SECTJRITY UEPOS.IT
5. l As security towards compliance of its obligations under this Agreem.cnt, WDL agrees
to pay to lREO an interest free rct\.!ndable deposit equivalent to Rs. 4,71,70,87,000
(Rupees Four Hundred Seve11ty One Ci:oi:e Seventy Lak:h Eighty Seven tl1ousand
Only) ("Refundable Security Deposit"). Out of the Refundable Security Deposit an
an1ount of Rs. 3,33,33,15,000/- (Rupees Three Hundred Thirty Three Crore Thirty
Three Lakh Fifteen Thousand Only) shall paid by WDL to IREO simultaneously with
the registration of this Agreement and WDL GPA. The balance of the Refundable
Security Deposit shaH be paid by WDL to IREO in the follow1ng manner:
(i) An amount of Rs. 63,37, 72,000 (Rupees Sixty Three Crorc Thirty Seven Lakh
Seventy Two Thousand only) shall be paid by WDL to IREO on the expiry of
180 days from the EHective Date or within 30 (thirty) day8 of lREO obtaining
tho approval for the Additional Lands and concomitant change rn Zonal Plan in
accordance with clause 8. l below, ,:vhichever is earlier.
l
·'
lrco I'rivat,c Limited

'"°'"'' O~m
Limited J l'rl"" O=m)!
Private L:tltcd
I
Ro>lt"" RTVS .L.., """"
Lilllittd
o
oasc. "
Limited I
i
,oxp11rb, l'nvllfe
· 'Ii
Adson Softw:ire'friv:itc Limited
Bl
Aspirant ildcrs
Private~Linjted
!lolb Ro,l~n Mm«
Limited ,
1
Five rivers De
Limited t lopers Private CnmJ der Realtors
Private,l,imited
&
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355
lt is agreed that os security towards the obligation of IREO towards payment of

Service Tax as provided in Clause 7.27 herein, an amount of Rs. 15,00,00,000
(Rupees Fifteen Crore) out of Rs. 63,37,72,000 (Rupees Sixty Thrcs: Cnm:
Thirty Seven Lakh Seventy Two Thousand only) shall be deposited by WDL on
behalf of IREO in an escww account opened for this purpos<i! ("Escrow
Account"),
lREO shall be entitled to the above stated amounts lying to the credit of th~'.
Escrow Account after it has complied with the obligations stated in Clause 7.27
and received a written consent in this regard from WDL. WDL shall be: t.:ntitled
to withdraw the said amounts along with interest that may have accrued on the
same in accordance with clause 7.27, from time to time, in the event IREO
dcfo.ults in complying •,vith its obligations therein and utilize the same towards
payment of Service Tax. The balance amount, if any, in the Escrow Account,
after fulfilling all the obligations related to Service Tax of JREO under this
Agreement and Other Documents, shall be the entitlement of IREO and WDL
shall forthwith hand over the same to TREO. 1REO shall bear .ind pay all
charges, fees and other related costs and expenses relnting t0 1'he Es<.:row
A.<.'.COunt. In the event IREO defaults in such payments, \VDL shall h0 entitled to
pay directly to the Escrow Agent and claim refund from the IREO.
It is clarified that notwithstanding deposit of Rs. 15,00,00.,000 (Rupees Fifteen

Crore) in the Escrow Account and/ or the withdrawal of the amounts from the
Escrow Account by WD L (if required), the amounts shall at all times be treated
to have been paid to IREO as part of the Refundable Security Deposit on the
date the same were deposited in the Escrow Account Taxes. if any on the
interest accrued in the Escrow Account sha!l be payable by IREO, and the
escrow agent shall be required to provide the TDS certificates in the name ur
!REO.
The Escrow Account shall be opened under a mutually agreed draft/ frmnat or
cscro._;v agreement, or a draft/ tbrmat that the escrow agent may provide;
(ii) An amount of Rs. 75,00,00,000/- (Rupees Seventy Five, Crore only} ("Balance
Sc<.:urity Deposit") shall be paid by WDL to IREO pursuant to the sanction of
the final building plans approved by \VDL and Environment Impact Assessment
Approval for Project-Subject Land,<;, in such timelines / instalments as may b,:
mutually agreed to ben:veen IREO and WDL.
5.2 WDL shnH be entitled to receive reillnd of the entire Rcfondablc Security Deposit in
the following manner:
I
{
/4
Watsonia l)cvclopers Private
Limited
r
Ornamenfil ReJtllor~
Private )limited
8TVS duildwcll Private
Limited
i I
Aspirantn~ilr.kr, Bulls Reaffor.- l'rivah•
Limited '
,-\<ls()n SufrwmlJ'rlvate Limited Private l1mitcd
' ,.
Iii\
Fiverivers lielopcrs Privnte Comman~r Realtors
Linritet: Private Umitw
&
TRUE COPY
356
33
(H On IREO's BUA being sold before completion of the same, the Net Sales
Revenue collected from lREO's BUA shall be adjus'ted towards the Refundable
Security Deposit as provided in Clause 6.2 (iii) below.
(ii) Up,in completion of the IRE O's BUA if the entire amount of Refundahle Security
Deposit is not received by WDL as per Clause 5.2 {i), lR.EO shall forthwith
refi.md the balance amount to WDL. Notwithstanding any other right or remedy
available to vVDL under Applicable Law, IREO shall be liable to pay an interest
@ l 2% per annum compounded annuafly to WDL .in the event of any delay or
default in this regard fbr the entire delay period.
5.3 The Refundable Security I)eposit is an interest fr~c deposit. Ho,vever, in che event
IREO foils or de fays to c,)mply with any ofthe IREO Obligations under th is Agreement
within such timellnes as is considered reasonable by WDL, the Refundable Security
Deposit will become an interest bearing security deposit fr>r such delayed period. TREO
shall be required to pay an interest of@ 18% per annum compounded annually on the
Refundable Security Deposit for the entire period of such delay/ extension.
6 BRANDING, MAR~'"ETJNG & SALE
6. l The entire Project~Subject Lands shall be branded, marketed, advertised and so!d in the
name and manner and under the lmmd and logo as WDL may deem fit, including under
the brand and logo of WDL or its Affiliates or group companies, To ensure maximum
realisation and. to avoid confusion in the market place and for other pertinent reasons,
IREO shall use the same brokers, channel partners and all servi<,c providers for ~ale of
entire IR.EO's BUA as WDL uses for sale of WDL 's BU.A. The name and logo ofthc
Project-Subject Lands as decided by \VDL, shall be used for all marketing materials
including all marketing communication, brochures and advertisements. WDL and
!REO may decide upon fimher terms, ff any with regard to hrand1ng.
6.2 Each party shall be free to dispose, sdl and transfer their respective saleable areas and
enter into agreements with the prospective purchasers as it may deem fit. WDL shall be
entitled to sell, transfer or dispose of the saleable area in the WDL's BUA and collect
and appropriate all revenues thereof in the manner it deems fit However, it is agreed
and understood that IREO and Land Owners shall comply vvith the following in process
of sale ofIREO's BUA
(i) In order lo ensure maximum realization, IREO umfo iakes and affirms that it
1
shall at all times price the saleable area/ units in the fREO's BU/\ at not lc::;s
than the price at which WDL is pricing the units in the: wrn !s BUA from time
to time. Further, the pricing mechanism und product mix 1.vil! be similar to what
is being used by WDL for \VDL's BU,'\. A \
Watsonia lJpers Private Ornament I Realtors !ffVS numtcH l'rivate
lrcn Private lt···mitcd Limited ! Private Limited Limited 1
l I ~
Base Exports trivate ' A,pirnnt~Buildcrs Bulls Real~rs Private
Limited Ads1m Soft'!l'are Priv,tte Limited Private L/imited Limited
?rivat~ Limitc'.o
I~
Fivcrivcrs Totnsbip
~
Fivedvers IY;evelopcrs Prh·ate
Limited 'I
Commm !er Rcalton
Private I, im itcd
&
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357
34
(ii) All allotment documentation in respect of IREO'::, BUA shall be in th~ formats
as may be used by WDLfor WDL's BUA.
(iii) The Net Sales Revenue (i.e. the basic sale price, the preferential location
-charges, car parking charges, club house membership charges, EDC, TDC,
power backup c,·harges, transfer tees, legal charges, cancellation / forfeiture
charges, interest on delayed payments and aH such other similar charges that
can be retained by a developer / promoter of a project of a similar nature)
collected from allottees / purchasers of IREO's BOA shall be deposited in a
separate bank account opened by IREO in this regard towards refund of the
Refundable Sect1rity Deposit TREO, wilt provide an im.ivocable standing
instruction {or enter into a tripartite agreement as may be required by WDL) to
the said bank account for transfer of all amounts collected in this account to
WDL's designated account forthwith, which instructfo11s will not be varied by
JREO and/or the bank ·without prior \Vritten consent of WDL. WDL will provide
the details of the bank account to which such trans for has to be cffocted prior to
launch of the Project-Subject Lands. IREO agrees, undertakes and confirms that
such instructions shall be maintained and the Net Sales Revenue collccts?.d for
the TREO's BUA shaH be .transferred to WDL's designated account, as stated
above.
(iv) Other Charges (i.e. service tax, VAT, stamp duty, registration charges and all
other similar charges that are required to be transferred / deposited to a
Government Authority) shall be collected by IREO in the manner it deems fit.
IREO will utilize / deposit the Other Charges \Vith the relevant Government
Authority as per the Applicable Law.
(v) It is agreed and understood that· WDL shall be entitled to rt:c-.:iw, rctuin and
utili:t:e in the manner it deems fit the IFMS / IBMS / maintenance charges and
ECC that are to be collected from the allottees / purdiascrs of the saleable area
of the entire Pl'qject~Suqjcct Lands. lREO undertakes and affirms to collect and
deposit such charges collected from allotment/ sale cf IREO's BUA directly in
lhe name of a bank account of WDL or of the maintenance agency appQinted by
WDL, details of which shall be pr()vided by WDL to IREO prior to launch of
the Project.
(vi) IREO and WDL may collect stamp duty and registration charges for sale /
allotment of the lREO's BUA and \VDL's BUA, r.::1;pective!y, and utilize it in
an appropriate manner.
/l
Jreo Privat,ilimitcd Umik.d

£/\
Wntsonia Developers Private
J
Ornameni.! Realtl)r~
Lii.itcd
f'rivnte
\.
I
i
BTVS ll!II wdl Private
Limlte,l l
!lase l~xport l'rivatc Aspirant i' ildc rs

Limited l Ad'"" SJm P,int< Limited f'rrvate Liniited
Ji
Fivcrivers T(m~l ship

Privlltc Limite! Fimi,on ~'''''"' '''""
Limited
Comm.in !1
t'rivate Lited
Realtors
&
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358
35
7 MUTUAL UN.DERST.A.NDING, COVENANTS ANl) OBLIGATIONS
7.1 In consideration of performing / undertaking, their respective specific and separate

obligations under this Agreement, WDL and IREO are each entitled to the revenue
from sale of their respective Saleable Arca, as provided in this Agreement i.e. lREO
shall be entitled to the revenue from IREO\; BUA, when the same is sold to third party
allottees / purchasers and WDL shall be entitled to the revenue from the WDL's BUA,
when the same is sold to third party allottees / purchasers, in accordance with the terms
of this Agreement. The authorizations given by the Land Owners and IREO to WDL
are to facilitate the construction I development process and the process of sale /
allotment of the WDL's BUA. This Agreement is not to be construed as transforring !
conveying ownership on the Subject Lands and / or the future construction on the same
in favour of WDL and/ or IREO. The ownership of the Subject Lands shall continue to
remain with the Land Owners until the same are transferred / conveyed to the allottees /
purchasers of the Saleable Arca. WDL shall have an unequivocal right of specific
performance of this Agreement along with all injunctive remedies as provided in clause
17 below.
7.2 It is agreed and understood between the Parties that WDL has entered into this
Agreement relying on the representation of IREO and the Land Owners that IREO
possesses development rights on the Total Lands, which it acquired by virtue of duly
executed and binding document:, i contracts. There is no restriction on IREO to execute
and enter into this Agreement on the tenns hereof.
7.3 \VDL shall be free to get this Agreement and WDL-GPA registered at the office of the
jurisdictional sub rcgistrnr and IREO and Land Owners shall present itself through a
duly authorised representative al th;.; said office for execution and registration thereof.
All costs, charges, duties and expenses incurred in this regard shall be borne by "\VDL.
7.4 It is agreed and understood between the Parties that all focilities, amenities and
common areas constructed as part of the Project- Subject Lands including the
community centre, club house, shops, swimming pool, tennis couns, other common
areas (the "Subject Lands Facilities / Common Areas") shall be for the exclusive use
and utilization by the owners of apartments constructed as part of the Project-Subject
Lands. The ovvners/ occupants of the apartments constructed as pa11 of the Project-
Remaining Lands shall not be entitled to access, utilize or claim the Subject Land
Facilitic::i / Common Areas. WDL shall file a dee<l of declaration under the Haryana
Apartment Ownership Act, l 983 and its rules in respect of the SuJ:tiect Lands and create
¼
lreo Prhfe Litoited
w,.. ,,;, !::pm!',;""
Limited
Om=.,t ""'"'D
Private ~ilmted
DTVl."j,w,11 r,w, ..
Limited 1
Base Expits Private

Limited
1\
Adson Softw11T1,.';.ivatc Limited
Aspiran~ulldcrs
Private Limited
Bulls Re.iri(rs Private
Limited
F;,em>,Jowmh;p Fi,orl,<,s o,,1p,N Prl"" C,mm,i, R,,.h,o

Private Limited Limited rriv,1te r,;mited
&
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359
36
an association of the owners of the apartment~ constructed on the Subject Lands, as and
when and in the manner deemed fit by WDL.
7.5 It is agreed and understood between the Parties that all facilities, amenities and
common areas constructed on tbe Remaining Lands includ1ng the community centre,
club house, shops, swimming pool, tennis conrts, other common area (the "Remaining
Lands Facilities I Common Areas") shall be for the exclusive use and utili:ration by
the owners of apartments constructed within the Remaining Lands. The owners/
occupants of the apartments constructed in the Subject Lands shali not be entitled to
access, utilize or claim the Remaining Lands Facilities/ Common Areas. IREO shall be
entitled to file a Deed of declaration under the Haryana Apartment Ownership Act,
t 983 and its rules in respect of the Remaining Lands and create an association of the
O\vners of the apmiments constructed on the Remaining Lands.
7.6 SimultanGously with the execution of this Agreement, possession of the Subject Lands
has been shared with WDL, for implementing the WDL Obligations and receiving all
benefits/ entitlements of the WDL Rights. WDL confirms that the possession of WDL
is only to undertake the obligations and entitlements of WDL under this Agreement
7.7 Certain areas forming part or the Project Lands have been earmarked / reserved for
r,oads as per the master plan for Gurgaon and the Zoning Plan for the Group Housing
Colony as appwved by the DTCP. The Parties agree that thf: proposed service road
abutting the Subject Lands and as demarcated in grey colour in the plan annexed as
Schedule-Ill, shall be constructed by WDL al its cost and expense.
7.8 In the event the Revenue Rasta is, shifted out of the Projeet-Su~ject Lands in
accordance with clause 3. 7.1 above, the land area of the existing Revenue Rasta shall
also be utilised in perpetuity for exclusive use of the Project-Su~jcct Lands in
accordance with the conceptualisation / design !:bat \VDL prepares for the Project-
Subject Lands.
7.9 It is agreed between the Parties that in the event any connection relating to facilities
such as electricity, sewer and water cannot be obtained separately for the Project-
Subject Lands and the Project-Remaining Lands, the said conncction(s) shall be
obtained at the Project-Subject Lands from the concerned authority. However, adequate
access to the said connections/ facilities shall be provided to the owners / oecupams of
the apartments constructed on the Remaining Lands, at the cost and expense of IREO.
Adequate provisions shall be made for measuring the consumption separately for the
Project-Subject Land;; and the Project-Remaining Lands, in accordance with Applicable
Law.
i:e\
{
!
*
,~\
lreo PriVate ~imitcd
Watsonia Oevelojicrs Private
Limited
Orn"'' "~t,.,~
Priv:1te Limited
trr\l's\,nuildwell Private
Limited
~
[" \
[l:'tsc Export.!/, l'iVate
Limited
ll
Adson. Software 1~1vate Limited
AspiraJlu ildcrs
Private Umitt.-tl
nun~ ~ea Ito rs Private
limited
1
(,
l'!Vcnvers
IT . 'fi
c1wnship fivcrivcr~ Devc!J,ers l'dvatc Corrnnajder Realtu1·s
Private Li1llitcd Umitecl 1 Private Limited
&
TRUE COPY
360
37
7. 10 Parties shall construct and develop the Projects-Subject Lands on the Subject Lands in
compliance with the License, sanctioned plans and in compliance with the Approvals.
7.1 l WDL shall be entitled to do all things, deeds and matters pertaining to all of the
development activities on and in relation to the Subject Lands in exercise of WDl.
Rights and for the purpose interact with any Government Authority or any other person
in respect of any acts, deeds, matters and things which may be done or incurred by, and
as have been agreed under this Agreement, and to sign all letters, applications,
agreements, documents, court proceedings, affidavits, and such other papers as may
required from time to time in this behalf.
7. 12 WDL, the Land Owners and IREO agree and covenant that at any time airer the
execution of this Agreement, and except in accordance with the te1ms hereof, they shall
not enter into any agreement, commitment, arrangement or understanding with any
person which shall have the effect of creating, directly or indirectly and whether
immediately or contingently, in favour of such person any right, interest, title, claim or
Encumbrance in or over or in relation to the WDL Rights, JREO Rights, the Subject
Lands or the Project-Subject Lands.
7. l3 WDL, the Land Owners and [REO shall not and shall ensure that no other person,
acting under or through any of them, does any act of commission or omissi.on that (i)
interferes with or causes any obstruction or hindrance in the <ixercisc of any of the
WDL Rights by WDL, or (ii) interforcs with or causes any obstruction or hindrance in
the exercise of any of the IREO Rights by IREO or (ii) whereby the WDL Rights or the
rights \)f \.VDL in respect of the Subject Lands arc prejudicially or (iii) whereby IREO
Rights or the rights of lREO in respect of the Subject Lands are prejudicially affected.
Without limiting the generality of the foregoing, neither WDL, the Land Owners, IREO
nor a".ly of their representatives or agent,; shall interact with, apply to or appear before
any concerned Government Authority or any third party in respect of the Subject Lands
or the Projects-Subject Lands except for development of Project-Subject Lands and
obtainment of Approvals as provided herein and shalf not interfere with the use or quiet
enjoyment of the Subject Lands a,'3 set out herein. 1n perfonnancc of its duties and the
exercise of its rights, powers and authorities under this Agn!ement, WDL . IREO and
Land Owners shall act in the best interests of each other ,md shall not, in any manner
what<ioever do any act, deed or thing that is detrimental to or against the interests of'thc
other.
7.14 The Land Owners and IREO have fenced the Subject Lands and Additional Lands
afong its boundary after obtaining alt necessary sanctions / approvals from the gram
panchayat and after settling all objections {if any) of the local vil!agers.
<kiJ ~ \
-~V' \Vutsonia Developers Private Orn,me.~"'1<oo BT~S Uuihlwel! Private
frco Privatr,irnikd Limited Privute Limited
Lilllitr .
Base Expmtii 1'1iv1ttc
Limited
1
Ad,oo Soitw>'< 1,.~ Um;<od
A.~pir.1nt l,ildcrs
Private Limited
Hulls #cal,or~ Pnvatc
Umiti::d
Fivcrivcrs ·~ownship
Private J ,imitcd
Fivtrlvcrs Devch~ers l'rivaie
Limited ,·
Comma t. r Realtors
Private tited
&
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361
38
7.l5 In the event of any disputes, claims, demands, suits, complaints (including customer
complaints), accident, death. contractor dispute, litigation, is/are raised, filed, occur or
created in relation to the Project-Subject Lands, then the Party responsible for it shal I
be liable for the same and settle and contest the sam.e at its own cost, risk and expense.
T11e Parties shall keep each other indemnified in this regard. In the evem them is any
dispute, claim, demand or suit in relation to the title and/ or possession of the Land
Owners on the Total Lands or on the rights vested in WDL under this Agreement, the
same shall be settled by IRE() and Land Owners, at their own cost and expense. IR.EO
and Land Owners shall keep WDL indemnified in this regard.
7.16 The Parties shall comply with all laws including but not Hmited to workers, guidelines
& notifications of DTCP, Income Tax Acti 1961, VAT., \VCT, Service Tax, PL
construction workers tax, including all others, as currently applicable and those that
mny be applied in future, pertaining to Project-Subject L2nds/implcmcntation of the
Project~Subject Lands/sale of the WDL's BUA and sale lREO's BUA/ maintenance of
Project-Subject Lands. Service Tax that may be appJicab!c in respect of this
Agreement shalt be borne and paid by IREO.
7.17 WDL and lREO shall ensure that their respective contractors take adequate insurance to
cover the construction perils and risks.
7. 18 Entire payments towards EDC, !DC and IDW (and any enhancement thereot) as
p;iyabk: in respect of the License till date have been paid hy lREO. Any demand made
thereof in future shall also be paid by IREO at al! times. All costs which may be
required for further renewal of the Approvals and License shall be paid by lREO. IREO
shall at all times maintain the Infrastructure Development Works bank guarantee with
DTCP at its cost and expense.
7.19 The remaining FSI out of the Total Project FSI shall be utilized by IRRO on the
Remaining Lands ("FSI-Remaining Lands") or on any other parcel of land as may he
p:!rrnittcd. It being also clarified that in the event Total PrQject FSI is increased at uny
time in future, such i:1creased FSI shall be the sole and absolute property of IREO and
in no event WDL or IREO shall c;onsume FSI in excess of the PSI-Subject Lands or
density in excess of the Density-Subject Lands on the Subject Lands. In such an event
or any increase in Total Project FSI, all additional License obligation$ will be a part of
the lREO Obligations. Similarly, any reduction in the Total Project FSI due to road set
back or acquisition of land by authorities for roads, shall be effected from the FS ! ~
Remaining Lands only and such reduction in FSI shall not affect FSI-Subject Lands.
7.20 It being expressly agreed that other than the IREO's Costs, fREO shall not be
responsible or liable to spend any other amount with respect to the Project-Subject
Lane.ls and all other Jmoun;s, costs and expenses req~ired to be spent/(ncurred on the
tt> J! 11 ~,
,~ Wat~Qnia .Bh.lJopers Private OrnamcntlRcaltors ln'V~ BuitdweH Private
lrco l'rivafe Limited Limited Private Lirttfted Limited
Basi) Exp,ts Private

Lhnitd i' l
Adson Software Arivatc Limited
Aspfrimtihlildrn,
l'rivutc Lynited
Hulls !altors Private
Limited
Fivcriwr~ \owmhip Fivcrivers De,·eliers Private Commanlr Rt,altors

l'rimte Limited Limited Private Umite<l
&
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362
39
Project-Subject Lands shall be the sole and absolute liability of WDL.
7.21 All communications received from the Government Authorities that may pertain to the
Subject Lands / Project-Subject Lands, shal.l be shared by lREO / Land Owning
Companies with WDL within 48 (Fo1ty) Forty Eight hours of receiving the same.
7.22 ln the event any issue I dispute is raised by any Government Authority or Person
inctuding the local residents / villagers with regard to the fencing / boundary of the
Subject Lands, the same shall be resolved by IREO at its own cost.
7.23 ff so requested by WDL, IREO shall, itself or through its affiliates, provide
Management Technical Services relating to the Prnject, based on its experience and
resources in development within the vicinity of the Subject Lands.
7.24 In the event lREO defaults to perform any of IREO Obligations under this Agreement
or if the Land Owners fail to perform any of their obligations, within such time as
considered reasonable by WDL, WDL shall be entitled to step in and undcrtah all sucb
acts, deeds and things as may be required to achieve the obligation that IREO defaulted
to undertake, at the cost and expense of IREO. IREO shall reimburse such amounts to
WDL forthwith upon receiving an intimation of such expenditme from WDL. ln the
case of any delay in such payments, an interest 18% per annum .~hall bt: payable by
IREO (() WDL for the entire delay period. ·
7.25 fREO sh,ill undertake and perform all lREO Obligations i lREO-Subject Lands
Development Obligations within such timclincs as is considered reasonable by WDL
and / or within such timelines as arc devised along with the landscaping,
conceptualization, planning, architecture, construction & design of the Project-Su~jcct
Lands prepared in accordance with Clause 3.2 above. ·
7.26 It is expressly agreed that though IREO wil! be consulted for demarcation of t!K· built
up area as per clause 4.2 above, the decision of WDL shall be final and binding in that
regard.
7.27 rt is agreed that Service Tax applicable on the [RI.::<.Ys BUA mtd WOL 's !3UJ\ M\d ~my
future alterations to the same as also on any other transactions between IREO and WDL
where it has been agreed that service tax is to be borne and paid by lREO, from time to
time, under this Agreement and Other Documents, shall be borne and paid by lREO. ln
respect of the IREO's BUA, fREO undertakes to pay to WDL the Service Tax, within 7
(seven) days from receiving an invoice i.n this regard from WDL. WDL shall raise the
said invoice upon demarcation of the IREO's BUA and WDL's BUA as per clause 4.2
J,~'.
of this Agreement, or at such time as the said Service Tax may accrue under Applicable
In the event
JREO 1ultsin making such Servt
Tax payments, IL
shall be
~ Wat~onia Dev~rs Private Ormiruent~\Re:llton irrvs nuf\iwelt Private

!n~o Private i·.mitcd Limited . Priv1lte ),imited Limited !
111 ~ R
8Jsc Exports 'rivatc
Limited ~
t
Adson Softwur~I Private Limited
Aspirant\1uildcr~
l'riva(e rmitcd Limited
!~
Ilulls Real~rs Private
Fiveriven To~~ 1sniJ? Fivc.•rivets Dev~lpers Private Commatlcr Rcalton

l:,ivate Umitc~ Limited Ii' l'rivak Limited
&
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363
ANNEXURE A-3
To
Ms. Srimathi Prakash
Executive officer - Discipline Directorate Dt: 07-09-2020
ICAI, New Delhi
Subject: Rejoinder to the reply filed by CA Vinesh Jain (Membership No.087701), Dt.18th August 2020
Reference: File Ref No. PR-81/2020-DD/108/2020
Respected Sirs & Respected Madams
I have provided here my rejoinder divided into Chapters for ease of reading.
......_
Best ~egardL' •
Ramesh San~
9810609241
--
""
.......
&
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.......
364
PRELIMIARY POINTS "1" - Personal attacks on Ramesh Sanka by CA

Vinesh Jain
.....
CA Vinesh Jain (VJ) resorted to Personal attacks. These are simply diversionary tactics. I will
NOT retaliate, but I would like to clarify each & every point: (for reasons of brevity, not
attaching proofs, but I can submit the same if required)
a) Actions taken by Statutory Authorities & Judicial forums against IREO group in the last
12 months:
i. On 13.09.2019, Govt of India has ordered SFIO investigation into the entire lreo
Group. -..
ii. Hon HC of Delhi has ordered dt 12th March 2020, Forensic Audit of entire lreo
,......
Group.
iii. in March 2020, SFIO has issued LOC against 10 of the lreo Senior management of
lreo RESTRAINING THEM TO LEAVE INDIA
iv. In December 2020, Hon NGT ordered SEIAA, Haryana & HSPCB to take action "'"'
against lreo for illegal construction of office building.
v. In July 2020, Hon CM of Haryana ordered Police investigation into the three
different/ FORGED copies of Sale deed 5144 available in three of the
Government Departments.
vi. In March 2020, Case has been filed in Hon HC, Chandigarh against the four
Benami sale deeds in name of "Global Estate" partnership firm owned by
Mr.Lalit Goyal 95% and his wife 5%
vii. Income Tax department has investigated, Assessed and rejected the false/ fake ....,_
purchases of Development Rights purchases accounted by lreo Private Limited.
viii. GST department has received total of Rs 23 + 6 = Rs 29 crores of Tax evasion
....,
already. In addition, GST department informed Hon HC, Chandigarh that lreo
evaded taxes of Rs 727 Crores, backed up with detailed transaction by
transaction and calculations based on transactions running into several
thousands of pages. All
these transactions files were provided to
GST dept by none other than Mr. Vinesh Jain.
ix. On 25th February 2020, Mr. Lalit Goyal (VC&MD of lreo) & his wife Ms. Sapna
Goyal were detained at Delhi immigration when they were fleeing from India
and were told not to leave India.
X. CA Jai Bharat Agarwal, Gr CFO of lreo and Mr. Subhashish Lahiri, Legal Head of
lreo declared "PROCLAIMED PERSONS" by Saket Court. Both were arrested
from the premises of NCDRC and were let off on interim bail. But VJ did not --.,,_
make any disclosures. There are more Non-bailable warrants and Proclaimed
Persons orders against lreo management. As auditor. VJ was sitting with Mr. Jai
and Mr.Lahiri during auditing. but VJ never informed police about the presence
of these proclaimed persons in office.
xi. ICAI has declared four statutory auditors "GULITY" in Primafacie opinions. Only
Mr. Raj Agarwal filed Review and other three did not file any review.
xii. ICAI has declared Mr. Nitin Gupta ( VP Finance of lreo Group) "GULITY" in
Primafacie opinion. VJ did not file any review.
....
&
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365
xiii. lreo Homebuyers :There are 1499 cases filed by lreo homebuyers in
SCDRC,NCDRC, District courts. In many cases, more than one homebuyer is
involved. In total more than Rs 7,000 Crores of homebuyer money is stuck in 13
partly finished projects of lreo and more than 6,000 customers are suffering
because of diversion of money from these projects.
xiv. PNBHFL, HDFC Ltd, Axis Finance have taken haircut running into several ,...,
hundred of crores of rupees because lreo Fiveriver, Puma Realtors, lreo
waterfront, lreo Private Ltd has gone under either IBC or under SARFAESI. .....
xv. Mr. Vinesh Jain is clearly aware of all the above, but not included any of these
disclosures in his report, instead chose to mislead ICAI by providing wrong --
replies.
xvi. There are many more such fraudulent actions and ALL ABOVE POINTS SHOWS
THE CHARACTER OF IREO GROUP MANAGEMENT.
.,...._
......_
......
,-,.
-
3 .....
.....
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366
PRE LIM IARY POINTS "2" - FACTS & TRUTHS ABOUT PERSONAL ATTACKS MOUNTED
BY MR.VINESH JAIN(VJ) on me
,.....
i. SEBI order has been enclosed by VJ in pages. SAT( SEBI Appellate Tribunal) has
reversed this order.(VJ is aware, but has hidden this info in his reply). SEBI
approached Hon SC and NO stay has been granted against SAT order.
ii. Trilegal & AXON Letters to ICAI have been filed with ICAI in August 2019,
.....,
October 2019 to canvass/ support for Mr. Raj Agarwal. ICAI has already proved
that ICAI can NOT be influenced by such letters by declaring Mr. Raj Agarwal
"GUILTY" purely based on merits of the case/ charges.
iii. Hon Supreme Court order has been misquoted by VJ ... para 20 of Order says ...
20 .... needless to say depending upon the outcome ofthe enquiry once it is
completed by the respective official respondents in their exclusive
jurisdiction under various acts, the appropriate action as provided in law
will follow against all those who are found guilty".
iv. lreo filed a case against me in 2018 With Gurgaon police and after
investigation, Gurgaon Police found that I have received all documents
thro legitimate sources. have concluded that "It appears that the complaint
had presented the complaints in question were presented as a counterblast
to the various complaints filed by the applicant/petitioner and Prima Facie
it is found and established that No Cognizable offence is committed and
therefore, these Complaints do not warrant any action ... ". But when the
whole country was under lockdown, Ireo once again filed the very same
complaint and managed registration of FIR on 30th March 2020. This
matter is subjudice now.
b) In DLF, I was signatory in all bank accounts. I was signatory for all transaction
documents. I was a Directors in many companies.
CONTRARAY, in lreo I was not a director, not even a signatory even for any single bank
account nor any signatory for any transaction documents. This clearly demonstrates
that I noticed Tax Evasions, frauds, diversion of money and I kept myself away.
c) lreo signed only a two page simple relieving letter whenever employee leaves, but for
me ireo has signed a 17 pages separation agreement when I left lreo. This shows that I ......
have opposed tax evasions, frauds & diversion of money in lreo and lreo tried to stop me
from informing Tax authorities about the tax evasions through this separation
agreement.
d) RTI s are not being misused by me, but have been properly used by me to bring out the
tax evasions, frauds & diversion of money in lreo. Tax evasions have been now collected
by Govt on my complaints proves this point beyond any doubt.
&
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367
e) I repeat .. I am the INFORMER to GST department and has brought out all tax evasions
to the GST dept. I have even helped GST dept in identifying transactions of tax evasions.
computations also.
f) I ONCE AGAIN REPEAT, I CAN PROVIDE PROOFS FOR All ABOVE STATEMTS, not
enclosing the same for reasons of brevity.
.......
&
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368
,....,
PRELIMIARY POINTS "3" .... DISCLOSURES TO BE MADE FOR MARCH 31sr
2020 BY S.N.DHAWAN IN IREO ANNUAL REPORTS.... HONESTY IS TESTED
........
1) For year ending 31st March 2020, S.N.Dhawan & Mr. Vinesh Jain needs to make these
following disclosures in the annual reports of lreo Group of companies and their honesty
will be put to test about the same related to :
• lreo entire group subjected to SFIO audit
• Statutory auditors declared "GUILTY" by ICAI in its PO
• OPENING BALANCES HAVE TO REDRAWN as auditors found Guilty by ICAI
• LOC issued against lreo management by SFIO & even Delhi police
• Detention of Mr. Lalit Goyal & Ms. Sapna Goyal by airport immigration
• RERA rejected registration of lreo Residences company Pvt Ltd.
• RERA has NOT approved Gurgaon Hills project even after 3 years of filing application
/ rejected its application?.
• GST show cause notice on non payment on receipt of Occupation Certificate
• GST show cause notices on various matters
• Income Tax rejection on purchases accounted for Bhiwadi Development Rights
,-,.
• Benami lands related to sale deeds 5144, 14477.
• Global estate does NOT own any land, then how lreo grace paid/ and also how 12
other Land owning companies can sign for exchanging lands
• Group CFO & Group legal head declared " Proclaimed Persons"
• Orders passed by Hon HC against lreo for Forensic Audit of entire lreo Group
• SARFAESI actions by PNBHFL, LICHFL
• Non Bailable Warrants issued by various Courts
2) Of course, S.N.Dhawan & Mr Vinesh Jain can avoid disclosures & give their own arguments
for non-disclosure of the above and be a part of lreo frauds. ......_
3) If S.N.Dhawan wans to protect the interest of Revenue of Government of India, Banks,
NBFCs, Homebuyers, Vendors then they must disclose all above facts and even many
~
-
6
......,
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PRELIMIARY POINTS "4": REJOINDERS FOR SOME PARAS :

a) Para 1. 3 of reply of Mr Vinesh Jain is illegal and has to be treated as contempt '""-
of Hon'ble Supreme court.
ICAI must note that the Hon. Supreme Court order was made with
observations .....
19 - So far as the raising of other grievances as set out ,....

supra by the writ petitioner against the other respondents
are concerned, suffice it to say, this court by order dated
11.07.2018 had issued notice to the official respondents
Nos. 7 to 11. These respondents pursuant to the notice
issued have filed their respective status report I elation to
the inquiries, which is being undertaken by them in their
respective jurisdiction. We have pursued the same.
20. Needless to say depending upon the outcome of the

inquiry once it is completed by the respective official
respondents in their exclusive jurisdiction under various
Acts, the appropriate action as provided in Jaw will follow
against all those who found guilty. r--..
b) There is lot of difference between a petition dismissed and court order made
with observation.
c) Mr Vinesh Jain's reply therefore is bad and illegal in law as VJ is saying
that Hon'ble supreme court dismissed my petition. VJ is knowingly giving a
false statement to the Disciplinary Directorate.
d) Para 1.4 of reply of MR Vinesh Jain is illegal and devoid of any basis, that
complaint is filed because of any motive.
e) Instead of submission of a professional reply.VJ has resorted to personal
attacks that too hiding full facts of each case and allegations. This illegal reply,
itself attracts provisions of Schedule to the chartered Accountant Act, 1949, a
member of ICAI cannot give wrong submission to ICAI in writing.
7 "'"'-.
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370
f) Para1 .5 is not in connection with this case, and knowingly this fact Mr Vinesh
Jain is writing an illegal comment and/or unfounded allegations, this
......
proceedings by SEBI. As informed above, SAT has already reversed SEBI
orders.
g) Needless to add these replies has no relevance to the matter under complaint
filed with ICAI.
h) Para 1.6 quoted by Mr Vinesh Jain, in respect of Court at Gurgaon, is irrelevant
as far as this case, is concerned.
i) The court at Gurgaon has admitted that civil matter is pending at before Hon.
Supreme Court, and as mentioned by us in this reply Hon. Supreme Court has
given a clear cut order with observations, for which Mr Vinesh Jain has made
an illegal statement in his reply that case was dismissed by Hobie' Supreme
Court, which is nothing but a contempt of the highest court.
j) In para 1.6 Mr Vinesh jain is trying to divert the attention of ICAI, which has no
relevance to subject matter and is purely a technical order, because the matter
was pending before a higher court.
k) Para 1.9 of reply of Vinesh Jain is illegal, VJ is trying to be spokes person of
Chartered Accountants, who has been already adjudged prima-facie "guilty" by
ICAI Disciplinary Directorate, VJ is trying to overrule the decision of of ICAI
Disciplinary Directorate, and making comment on such order by referring that
chartered accountant are suffering because of bonafide complaints filed by the
Complainant. This false, and a wrong statement made with full knowledge of ....,
Mr Vinesh jain attracts provisions of the Chartered Accountant Act.
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371
CHAPTER 2 .... REJOINDERS TO 2.1 to 2.10

1) ICAI is dealing with complaints on daily basis and hence is fully aware of the procedures and
processes to be followed including the Form 1 filling.
2) Mr. vinesh Jain is resorting to hair splitting and diversionary tactics to take ICAI away from
investigation into the non-disclosures, wrong disclosures and fraudulent disclosures made by
Mr. Vinesh Jain .
3) I will not offer any comments as ICAI is better equipped.
4) Para 2.4 (ii) MR Vinesh jain is making again an illegal statement knowingly to be false as VJ is
saying no further evidences can now be submitted.
5) ICAI can always ask for additional evidence. Thus, the entire reply of VJ is illegal, and is an ....,
attempt to thwart the disciplinary mechanism itself, by making either false allegations or even
commenting illegal statements on the powers of ICAI Disciplinary Directorate itself.
6) Para 2.4(iii) of reply of Mr Vinesh Jain is against the provisions of ICAI act, any person can make
complaint to ICAI Disciplinary Directorate, Mr Vinesh Jain also knows that in case of all the
complaints to ICAI, all other Chartered Accountants have been adjudged as " prima-facie
guilty", in case of IREO Group companies. His statement, knowing to be false attracts .....,
provisions of the Chartered Accountant Act.
7) Para 2.9 which states IPC code are not relevant to extant case, ICAI has its own Disciplinary
Mechanism. All the complaints made by complainant are very clear and unambiguous and
supported by full facts, for which VJ has failed to submit any convincing/valid reply.
,....
.,...._
.......,
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372
CHAPTER 3 - REJOINDERS TO 3.1 TO 3.28

1) I would like to repeat whatever I stated in my Complaint.
Mr.Vinesh Jain made wilfully these following:
• Non disclosures
• wrong disclosures
• fraudulent disclosures
• gross negligent disclosures
2) VJ is also in "hand in glove" with ireo management and helped lreo in evading GST and
Income tax to Govt Of India by suppressing transactions and even making false
statements.
3) VJ is also mislead homebuyers by not making proper disclosures on the status of the
projects, Cancellation of approvals, progress of projects etc.
4) Para 3.16.iii -- ICAI in its PO has declared "GUILTY" these following statutory auditors who
have audited more than 100+ lreo Group of companies
Mr.Raj Agarwal of SR Batliboi
Ms.Priyanaka Garg of Priyanka Garg & associates
Mr.Vijay Sharma of Vijay Sharma & associates
Mr.Anil Goel of Anil Amitta associates
Mr.Nitin Gupta, VP-Finance of lreo Group. ,......
so Mr.Vinesh Jain has made a misleading & false statement.
5) COMPLAINTS ARE RELATED TO WHICH GROUP COMPANIES OF IREO ... para 3.18 of reply
All my complaints are related to only 6 companies that were AUDITED BY MR.VINSH JAIN
ONLY & all complaints are related to 2017-18, 2018-19 only.
• ireo private limited

• ireo residences company private limited
• ireo grace realtech private limited
• ireo victory Valley private limited
• ireo hospitality private limited
• GP Realtors Private Limited
So all wrong disclosures, non disclosures filed by me in my complaint are fully covered
by VJ's audit only.
r'\.
6) SCNs (Show Cause Notices) being issued by GST department ( by 30th Sept 2020) will
clearly demonstrate how evasions have been done by lreo & how VJ has failed to disclose
such tax evasions intentionally. VJ is a part of tax evasions of lreo Group through non-
disclosures/ wrong disclosures/ fraudulent disclosures. { REQUEST ICAI TO
10
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373
PERMIT ME TO FILE IN OCTOBER INFORMATION OF THESE

SCNS)
7) Reply to 3.2s, to 3,28 :
I have first provided to VJ these following documents in my complaint

(a)copies of three occupation certificates issued by dtcp
(b) Apartment wise area in Sq ft related to the sold & unsold apartments ( these exactly
match the very audit files submitted to GST department by S.N.Dhawan )
(c) then I provided detailed calculations of tax visions
and after that only
(d) I have asked Mr Vinesh Jain why proper disclosures have not been made for year ,,..
ending 2018, 2019.
,....,_
(e) I did NOT ask for any information/ I'm not looking for any new Information from Mr
vineshJain
So VJ is trying to make false & baseless allegations that I was looking for information from
him.
......
,___
11
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374
,,--,
CHAPTER 4 - CHARGE 1 -..
1) 4.1 is already replied in chapter 3 point 5. My Complaints are all related to the six
companies audited by Mr. Vinesh Jain only. So VJ is squarely responsible to reply.
2) VJ himself has given the list of 8 lreo Group Companies, on page number 16 of his reply
and admitted that VJ is doing audit of these IREO Group Companies.
3) In his reply, to utter surprise VJ is asking what is the meaning of group companies? AS-21
........
clearly defines what are group companies, and being member of ICAI, if VJ has signed the
consolidated accounts of group companies, without knowing what the Group Company
means?
4) Not only this, VJ is supporting Mazars Mauritius for consolidating of accounts and hence
is fully aware of the 180+ companies getting consolidated at Mauritius level.
5) VJ is also aware of the case filed in Delhi HC by ireo investors in which lreo has filed assets
information of all the 180+ companies as per the directive of Hon. HC.
6) It is reiterated that Mr Vinesh Jain has failed to submit any valid reply on Charge 1.
7) We again categorically mention that Mr Vinesh Jain, Colluded with client i.e IREO Group
of Companies, wilfully, ignored to look the Occupation Certificate of various project s.
8) Reply to 4.2 to 4.8 :
PAYMENT OF DUTY VS REVERSAL OF DUTY
a. Mr. Vinesh Jain is trying to mislead ICAI on "reversal of duty'' where as the issue Is .,,...,,
related to "non payment" of taxes
b. As per Rule 6 of Cenvat Credit rules of Service Tax Act ,
i. (ii) the manufacturer ofgoods or the provider of output service

shall pay an amount equivalent to the CENVAT credit
attributable to inputs and input services used in, or in relation to, the
manufacture ofexempted goods or for provision ofexempted services
subject to the conditions and procedure specified in sub-rule (3A).
11. Similar rules are existing even under GST act.
c. Thus Service Tax and GST direct the "payment of amount equal to the ,,.....
CENVAT/input credit." These Acts does NOT demand on reversal of credit
at all.
d. So entire reply provided by VJ is absolutely wrong & misleading.

........
12
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375
Ireo already "Paid input credit" on these projects after reeiving OC and such
payments were made from 2015 & 2016 . (Proof is enclosed here once again for
Grand Arch and Uptown.)
■
Grand Arch Phase 1& phase 2, "
■
Uptown phase 1 & phase 2,
■ Victory Valley Phase 1,
■ Skyon Phase l
e. His conclusion in para 4.8(a) that Ireo need not have to pay duty is based
on "reversal of duty" and is illegal and VJ is trying to justify his illegal
act.
f. Mr.Vinesh Jain & S.N.Dhawan are auditing many real estate companies, that
means this tax evasion fraud after OC (occupation Certificate) may be in many
other companies audited by S.N.Dhawan & co? ·
g. lreo has further deposited further Rs 6 crores with GST Dept in January 2020 ,,.....
towards the GST evasion after receiving of Occupation Certificate. If Mr. Vinesh Jain
is correct, lreo would not have paid further money.
h. Reply to Para 4.8/bl - Issue in complaint is related to the input credit taken before
the receipt of OC and NOT about the input credit to be taken after the receipt of OC.
VJ is once again trying to mislead ICAI.
i. Pl look at page 110 of reply provided by VJ regarding duty payment and SEE HOW
VJ IS TRYING TO MISLEAD ICAI
.l&, .>e,..:,.. ..,..,.,~ ,.,..00'1 bulldl ng p l •n

l l. ,00, 4-18 Vwr-lned from bookl,... reol•ter-
5 . 38.0J.G
32.84
A.2S.00. 000
••••nc• lnpvc. In book•
( 6 l. ,0~,96A} Jonorcd
.:u s,sssseo DR.C ◄ .

... S G-44 ◄ 2 0 OR.C '1
•2•00000
j) Total saleable area is taken from "building plan" (This is based on FAR/ FSI as per Haryana
Govt rules) , but area sold is taken from "booking register" (booking area is "super area", ......._
which is generally 25% to 40% higher than the FAR area.
.......,
k) VJ should have taken both areas from building plan or from booking register. VJ can not
play with data picked from two different sources and use jugglery of maths to justify.
I) Also VJ gave data only for Skyon and Not for Victory Valley project payment of Rs 300 lakhs
... as these data taken from two sources also can NOT justify the amount paid on the day of
raid by lreo.
....._
......_
13
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376
CHAPTER 5 CHARGES 2,3,4 .....,_
,...._
1) Once again Mr. Vinesh Jain talks of "reversal" of input credit. But Service Tax/ GST directs
the payment of input credit taken on OC date and does NOT talk of reversal of input credit
which is related altogether to a different activities and not related to OC at all.
2) Mr. Vinesh Jain is quite clearly aware of the fraud VJ has committed by helping lreo in ,....,_
evading this payment of Tax. Hence VJ is just trying his luck by giving these misleading
replies to ICAI. ---..
3) Para 5.1, 1 & 2 - Lots of input credit is available in the books of companies is irrelevant. Just
having input credit in books will not give revenue to Govt, that input credit has to be PAID
to the Government thro challan.
4) By Giving information on the input credit balances available in the companies books, VJ is
clearly admitting that Payment has to be made and enough credit is available, but still lreo
did not pay GST intentionally.
5) lreo Private Limited(IPL) has a credit of Rs 24.38 crores as per data given by VJ. But IPL has a
total of six projects and the input credit figures given here are the total of six projects and
NOT OF SKYON PROJECT alone. So once again a misleading statement.
6) Similarly Input Credit is available in the books of lreo Victory Valley Pvt Ltd (IW) .
7) Credit balance available with a company has NO relevance as Govt of India gets revenue only
when challan is made and paid. So VJ once again trying to make misleading statements.
B) Paras 5.5 Ill
VJ admitted that on 18th October 2019, when GST dept raided lreo group, IPL paid Rs 825
lakhs, IW paid Rs 300 lakhs. In short, if no raid, no payment by lreo. Also this ..,.._,_
payment has been made after 2 years after receipt of oc ( two oc s received in Sept 2017).
Accounts of 31'1 March 2019 were signed by VJ in November 2019. So why VJ did NOT make
any disclosures even in 2019 and also why no disclosures were made in March ending 2018?
9) Pl note that IPL, IW paid lumpsum amounts during raid , actual payments of GST on unsold
apartments will not be a round figure. lreo actually paid whatever maximum that these
companies can pay on the day of Raid.SN Dhawan audit team was present in lreo office
during Raid.
10) Once again VJ tries to mislead by using the word "reversal" instead of " payment" of input
credit.
11) VJ gives illogical reasoning that provision of Rs 825 lakhs has been made in books of IPL as
on 31st March 2019 for the payments made 18 October 2019. SKYON OC received on 14th
September 2017. VJ does NOT give explanation of what happened when books were
closed on 31st March 2018.
12) Similarly, IW OC has received on 27th September 2017. But Rs 300 lakhs paid on 18th
December 2019. So no payments made for almost 2 years. No provision during 31st March
2018 and VJ does not provide any reasons for non-disclosures in CARO for two years.
.,,,.....
13) Paras 5.6 to 5.8. VJ explains irrelevant paras related to CARO, audit procedures, etc.
14) Para 5.9, VJ justifies himself that Rs 825 lakhs amounts to 1.6% of the assets and hence no
disclosure made in CARO. It is a shocking statement. In CARO even a few rupees of Tax
evasion has to be disclosed and VJ must be fully aware of this requirement.
14
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377
15) Para 5.10, .. VJ goes on explaining irrelevant information Related to SA 250

16) Para 5.11, .. once again VJ tries to justify the non disclosure into CARO by comparing the
evasions vis a vis asset s value. This is a baseless argument. Rs 800 lakhs & Rs 325 lakhs are ...,_
very huge amount of tax evasions and must be disclosed in CARO.
17) Para 5.13, .. VJ has definitely signed false financial statements only
o by not calculating the correct amount of duty evasions,
o by not making provision for full payment of taxes evaded and
o by not disclosing the CARO,
18) Para 5.19.. lreo Corridors is the project developed by lreo Grace Realtech Pvt Ltd (IGRPL)
a) Corridors OC received on 31st May 2019
b) Amount equal to the input credit NOT paid by IGRPL on 31st May 2019. .....,
c) GST raided lreo and IGRPL paid Rs 9.68 Crores on 18th October 2019.
d) If no raid, no payment would have been made by lreo.
e) Annual Report was signed in November 2019.
f) As massive amount of duty evasion is a significant event, Auditor should have disclosed
the sam e in CARO or in auditor report of March 2019.
g) VJ did not bother to m ention the same in annual report.
h) VJ is not able to reply and hence avoiding replies.
19)Para 4.5 of reply of Mr. Vinesh Jain is totally illegal and evasive in nature. VJ is
referring the matter as theft, the paper which are having information and
submitted with our complaint were provided by REGISTERED INFORMER
WITH GST DEPT .
""'\
20)VJ's reply therefore, is liable to be quashed as VJ is not respecting the law of
the country and rights and confidentiality attached with the INFORMER /
Whistle blower.
21)The complainant has further explained on page 25 to 31 of his reply, which is
nothing but an attempt to hide the facts, the very fact the IREO has paid the
amount subsequently proves that his report was fraudulent and illegal, meant
to evade tax by IREO Group and VJ helped the IREO group in doing so. VJ
was also gross negligent in not reporting the tax so unpaid.
22)It was duty of Statutory audit in accordance with IND AS 11 , and IND AS 37, on
completion of each project, to appropriately recognise, all the liabilities of the
project, and account for the same in books. Mr Vinesh Jain not only did not
....
recogn ise such GST liability as per GST rules, but also failed to report under
CARO.
23)MR Vinesh Jain is referring to guidance note on CARO issued by ICAI, no
where this guidance note allows, an auditor to certify an audit report where
15
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......
378
liability is intentionally not accounted for by a company and compute arrears of

6 months from the date company has actually paid such liability.
24)1REO failed to pay the GST liability on the completion of various projects, which
falls under the audit of Mr Vinesh Jain, and MR Vinesh Jain colluded with the
client not to account for same and not only violated CARO reporting, but also "'
IND AS 37 ( to the extent liability was under reported on account of GST) and .,.......,
also IND AS 11 , as the expense of project i.e. GST expense was under booked.
25)Thus, guidance note on CARO referred by Mr Vinesh jain does not hold good,
this guidance note no where allows any auditor to under report GST liability and
......
get away from reporting .
26)1t is therefore, submitted to ICAI, that Mr Vinesh Jain:
a) Did not comply with reporting requirement under CARO for arrears of GST
not paid by IREO group of companies, of which VJ was auditor.
b) VJ failed to comply with SA 250, by overlooking and not reporting a material
violation of law by lreo Group of companies in evading massive GST liability.
c) VJ also failed to comply with IND AS 37, and IND AS 11 as discussed
above.
27)On page 39 of his reply Mr Vinesh Jain is referring to materially. It is submitted
that VJ is talking there also about Reversal of credit and not payment of duty
which is an illegal statement, knowingly as false, and as such this reply is ..,...,
invalid. _....,_
28)For CARO reporting dues are required to be shown irrespective of

materiality, as it is a statutory requirement under the Companies Act,
2013.
29)This is also pure violation of SA 700, 705 and SA 706 also being known
compliance of legal provision of the country. VJs allegation that resopondent
lacks knowledge of this subject matter is totally an illegal statement made by
him to ICAI knowingly to be false.
30) CONCLUSION OF CHAPTER 5
A) Conclusion 1 ➔ VJ HAS BECOME A PART OF TAX EVASION CRIME OF IREO Pvt Ltd , IREO
VICTORY VALLEY Ltd as
► Duties not paid for 2 years after receipt of OC for Skyon, Victory Valley
-
16
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379
► Duties paid only after GST team raided ireo (based on my complaint) ----.
► IF NO RAID, NO PAYMENT OF DUTIES
► When duty paid after 2 years, no mention of the same in CARO/ annual report
► CARO was signed almost 20 days after GST raid and after payments
► Even after duties are paid, VJ did not check calculations and made any provision in
accounts for full evasion amount.
► VJ ASSUMED that whatever is paid is what is the total tax evasion amount.
B)Conclusion 2 ➔ VJ BECAME A PART OF TAX EVASION CRIME OF IREO Grace Realtech as
► Corridors OC received on 31st May 2019

► Rs 9.68 Crores equal to the input credit NOT paid by IGRPL on 18th October 2019.
► No raid, no payment would have been made.
► Annual Report was signed in November 2019.
► No disclosures were made
,,...,_
,-...
,.,-...
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380
CHAPTER 6 - CHARGE 5
a) Corridors Project License was given to Precision Realtors Pvt Ltd. ,,......,
b) But Corridors Project was launched by lreo Grace Realtech Pvt Ltd. (IGRPL)
c) BIP ( Beneficial Interest Policy) policy announced for change in Developer in February 2015.
d) IGRPL did not apply for BIP and did not pay the required fees to Haryana Govt.
e) DTCP on 01/04/2016 clarified that projects without BIP will not be treated as illegal.
f) DTCP on 01/04/2016, para 2 made clear that charges/fees must be paid and projects must
apply for BIP.
g) IGRPL did not apply for BIP... HENCE IGRPL RECEIPTS FROM HOMEBUYERS IS IN CLEAR
VIOLATION.
h) IGRPL received OC for phase 1
i) OC for Phase 2 held up due to benami land, forged land deeds filed with DTCP
j) Homebuyers filed complaint with Delhi EOW police
k) Delhi police sought clarification from DTCP.
I) DTCP clarified that IGRPL CAN NOT collect money from homebuyers as BIP has not been
received by IGRPL.
m) One of the Homebuyer of Corridors has obtained all papers t hrough RTI only and shared
with me also including the RTI reply also.
n) Finally IGRPL paid BIP fees on 011-02-2019 and applied for BIP on 14-02-2019, as DTCP
to issue oc for phase 1 without BIP approval.
refused
o) Irrespective of clarification provided by DTCP, Auditor should have mentioned in
st
-
the CARO/ annual report of 31 March 2019 about non-payment of fees& delay of
fees by almost 4 years to Haryana Govt etc.
p) By referring to orders of 2019 of DTCP, VJ himself is acknowledging that facts stated in 2017
or 2018 were illegal.
q) D) This is blatant non-compliance of SA 250- Consideration of Law & Regulation and also SA
240 Consideration of Fraud. VJ has failed to respond any valid explanation. VJ is referring order
much later to his audit report date. Till such regularisation i.e. till 2019, his reporting was not
only fraudulent but was in non- compliance of law of the country.
Repeat portion of my Complaint :
5 a) DTCP thro its Jetter Dt 29-04-2019 written to EOW police ( pages .. 68 .. ) has clarified that /GR ,...._
can NOT collect money from Customers ( of Corridors ) till change of developer permission is received
--..
by IREO Grace ( letter enclosed)
--..
5 b) Same issue has been replied once again on 05-02-2020 by DTCP to EOW police. (
pages......... 68.... )
.....
18 --..
.-...
&
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381
5 c) /GR must & should have applied for BIP in 2015 itself when policy was announced. {
Pages ...... 70 to 74 .. ) as /GR does NOT have any DTCP or Government approvals like Zoning plan,
,,...._
Building Plans, Fire Scheme approvals in the name of/GR and hence
5 d) Irrespective of above clarifications in S{a) & S(b) 1 even as per the DTCP 8/P policy, THIS
COLLECTION OF MONEY FROM CUSTOMERS IS A MAJOR VIOLATION OF BIP POLICY OF HARYANA
GOVT /DTCP POLICIES I RULES & REGULATIONS. STILL AS STATUTORY AUDITOR YOU HAVE NOT
MADE ANY DISCLOSURES AND KEPT SILENT MISGUIDING ALMOST 1000+ CUSTOMERS OF IREO
GRACE. PLEASE EXPLAIN WHY NO DISCLOSURES WERE MADE BY YOU IN ANNUAL REPORT I CARO
OF /GR FOR THE VIOLATION OF 8/P POLICY AND COLLECTION OF MONEY FROM IREO CUSTOMERS
""'
VIOLATION OF 8/P POLICY AND COLLECTION OF MONEY FROM IREO CUSTOMERS?
5 e) IREO Pvt Ltd has applied for 8/P approval and received the 8/P approval for JDA with
Heritage Max in 2017 itself ( Pages ......142, 143 ......... ) Hence IREO group is fully aware of the BIP
policy requirements .
5 f) Have you obtained written explanation from IRED for violation of 8/P policy & collecting
money from Customers?

5 g) Haryana Govt has lost massive revenue related to BIP due to your non-disclosures in
Auditor report/CARO
'"'
19
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382
CHAPTER 7 ---- CHARGE 6 ,....
1) Total amount transacted between inter companies as follows, as per Balance Sheets: ,,..._,
a) lreo Pyt Ltd 2018-19 annual report :
24 lmo,1-,,- boanaftt. • ~ •
I, S alaries, wagfl and bonus 3,696.72 5,239.76
U, COntrtbutlon ta l)f'OVident fuM 1~.-49 23-4,7S
m. Greb.llty expenses (refu not• 29) 116.7S 128.89
Iv. Compennt.d .aibuncec 24'.02. 80.8..
v. Staff wena,e expenses 1S1.75
.,1,~w01
136,53
_)
Leu: Co'St- lllloc&t~d t o othe r c om~nlfl
j ~iilfi'
27 Oth•r •XD•n-■
I. Rent 1◄ 2.)2 145,84

II.
Ill.
Ra tes •nd tex. .
Offlc• rnaln~lnce
1 ,040. 00
36.0S
217. ll
178.25
,,....,
Iv. f\ep,-lr •nd ~ •n tenan ce - Plant and Mach inery :U,90 65. 60
v. Repair and Matntenance - Others 1,170.+4 1,484.90
vi. Power end Fuel 272,.Z8 388.39
vii. Travelllng end conveyance• 204.07 41◄ .27
viii. Communication expenses 89.95 126,J◄
Ix. Pt1ntlng a nd stationery 26.62 72.21
...
x.
xii.
S.nk charoe-s
Architect and design fee
Govemment dues and llc:cn.sc rcc5
86.37
49.58
1,683.70
239 .63
1,567.36
859 ,72
,_..
xiii. S t • ff ,-.,rultment e xpense• 4.62 8 . 99
XIV. Legal and profess ional charges 1,284.87 1,30~.29
xv. Securtty Charges 268.55 347.08
xvi. Claim and compenutJon expen5e 16,686.52 840.30
xvii.
x viii.
Guest house expenses
Advertisement and bu~nes, promotion expenses
25.03
149.90
28.86
190.20 ----
xix, Membe.rwhlp end .ub9criptfon 4.88 2 8 . SS
xx. Remuneration to auditors •• 12.93 17.00
xxl. Loss on sale of Nxed aaets 0.09
XXII. &rokeraoe and conwnts5'on on sales 720.86 676. 17
lOCIV. Corpor•t• 90Clal r csponslbtlitv expe nse 3-4 .35
xxv. Advances written orr 0 . 35 757.57
xxvl. CeP,ltel expenses written off 34.30
xxvll. Provision ftK <SoubtfUI ~vane-. 4 87.05
xxvlll. Exchang• dltferenc. . (net ) 1 0.09 2.44
xxlx. M lsceUanaous expen5e5
z..,i5i:Jj 10,i~;:~~
:) Less: Cost alloceted to other companies
ii-.,:.~f.:l.fl
9 '3US,43)
•• • 7 . 20 "
B) lreo Grace Realtech Pvt Ltd Annual report 2018-19 :
l■ .....,_ Nll.nta,NIII-
• • S.lenes end bonus 38,888,433 36,338,080
b. Contnbutlon to provident fund 1,861,173 1,7150,327
c. Grttulty txpente 1,318,293 1, 114,743
d. Compensated abuncn !152,054 378,4!111
• · Sta" welflre expen- 1,576,501 9!12,997
,.....
p.11-,'in
f. Colt tranftlftd II-om releted p,rty (reflr llott 27) 7 420 687
,dit~:u 22
20 othar-
.. Government d1111 and Ileen• r.a
b; Arctlit.ct ■nd dalgn fH
21,995,520
5,347,316
46,732,1150
13,522,883
C. LAg■I ■nd profwatonal ch■ !'llff 30,766,135 17,668,210
..,.
d. Advertllement ■nd busln• promotion expansa
R■tN ■rtcrtax•
Rant
!1,860,592
13,325,469
14,230,545
3,436,453
896,914
12,881,370
g. Offlce M■lnwn■ nce 5,547,800 2,067,742
h. IMUrlll'ICII d,arges 4,448,912 6,468,768
I. Power ■net Fuel 507,002 5,420
J. TnMllllng and conveyance 252,423 987,095
k. communlc■tlon expen• 519,754 515,485
I. Pr1ntlr19 ■nd stationery 190,718 221,866
m. Security Expe,ws 7,824,271 11,374,610
n. Cl■lma and compelll■tlon 40,549,220 1,387,792
o. Ramunentlon to auditors (m■r nota below) 273,284 250,000
p. Brok■rag• ■NI comrn1U1011 on sales 12,220,503 27,076,883
q. CSR e~ltllre 3,000,000
r. Provlllon for doubtful advancM (net) 528,727 217,540,678
s. Exchange loss (net) 1,333,713 24,086
t. MIS0ell1neou, expenNI 130,434 ....,
u. Cost tr■ lllflmd from r■ lated party (refer note 27) 3 15~, 269 9l111.sss
-? ln,i:ri, l7i *'' 10,ftt
20
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&
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383
Cl IREO VICTORY VALLEY ANNUAL REPORT 2018-19 ,-..
....,.
-v---., v- ~ .....-
,._,.,.... INS t(SN enwtd
.....
.,., .,000
-
,u....ooo
1:,Hl',OIO
.......
t , IJI.SSJ
~200,000 2",H.J,Sl6 )6,l00,000
U0,000 .....
1t1.on,2.w ...,oo,o,.
,.,_
•11,n t ,10$
.,,..., ...11
-
. ,.,.~.... _...... _ ..,.,. ___.....,...._ y
,.._
Dl IREO RESIDENCES COMPANY PVT LTD ANNUAL REPORT 2018-19
19 DecreaH / Clncra•-l In ProJecu In proar. . .

Opening ba"'nce (A) 4,106, 119,662 3, 509,486,134
Less: EKpenses transfer,.ed to related party (se e note bek>w) (77,224, 753)
Ck>slng balance (B) --,◄ce•,;,◄c:;0◄
;::,e','7:,:2:,,0".,;8:;,L7;.,...-.;,4'!-'.1c'06~•,;;1;;19;,.,.:e66;,o;:2~
Dec,. ._ I CEna••-> ln ProJecta In proor. .• CA•Bl c2N.001,1ss> (673.•u.2■1>
Note,
Expenses 1 ll~ted l o Ireo H05plt•llty Company Pr ivate Llmibed pertai nin g to
........
earlier years.
2:0 EMPlov. . Nneflt. • x pen. . ......
a. Salaries and bonus 85, 271,028 88,577,485
b. contrl b<Jtlon to provident fund 4,230,708 4,438,238
c. GrMultv expenses 1 , 108,938 760,82:l
d. Compensated absences 1,022,409 1,286,292
e. Staff welfare expenses 1,881,738 1,901, 593
f, S.lory cost allocated from related party (refer not• 29) 4,454.238 31350,042
Less: S alary cost a llocated to related party "
E) IREO HOSPITALITY PVT LTD ANNUAL REPORT 2018-19
23 Emplov•• benefits expense
a. Salaries and bon us 1 .16 1 . 26

b . St aff welfare expenses 9 . 16 7 .11
c. Cost al located from Third party 30.11
40.43
4 0.25
48.62
,,,....
21
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&
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384
,,....
25 Other expenses
a. Rates and taxes 46.02 0 . 91

b. Office malntena nee 15.13 7 .08 ........
C. Bank charges 10.53 7.82
d . Security charges 0.29
e. Power and fuel 5 .03 0.35
f. Travelling and conveyance 60.54 15.09
g. Communication expenses 1.21 0.72
h, Printing and stationery 0.70 6.96
i. R.emuneratlon to auditors (refer details below)"' 6.61 4.50
j. Legal and professi onal charges 25.20 3.86
k . Guest house @xpenses 0.24 0.77
I. Business promotion expenses 8.25 9.33
m. Brokerage and commission 0.41 0.71
n. CSR activity 7.64
o. Exchange loss (net) 104.00 25.83
p. Miscellaneous expenses 0.38 1.35
7 q, Cost transferred from thi rd party 24.05

308.30
46.46
139.67
1) VJ has not provided data that Taxes have been paid on A the above amounts. lreo has
raised few invoices as an eye wash and VJ has presented only those invoices here. VJ should
have given invoice copies of all the amounts OR at least should have provided details of
invoices numbers OR schedule details from the GST returns .
2) GST department is already issuing Show Cause Notice ( by end of September 2020) for the
non payment of Taxes on these inter company transactions with complete transaction
details.
CONCLUSION CHAPTER 6 ➔ GST has NOT been paid on all inter company
transactions of the lreo Group and VJ did not bother to verify the tax payments/ tax
evasions and did NOT report these tax evasions in CARO.
oP
pc,....5
.......
.......
,,...._
22
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385
CHAPTER 8 - CHARGE 7 ,,.....
Para 8.4
1) lreo has to PAY DUTY ON REVERSE CHARGE method if vendors are not paid in 90 days in
service tax regime/ 180 days in GST regime. (As per GST ac.t, "payment on reverse charge
.....,_
and not reversal of duty" )
2) Only after making payment to Vendors, once again input credit can be taken.
3) If credit is paid on reverse charge, then it will definitely have an impact on financials.
Materials cost/ contractors invoices/ professional services cost in the project goes up by .......,_
the amount that has been paid on reverse charge. So VJ's argument that these payments on
reverse charge has no impact on financial is absolutely wrong. ---.
4) VJ has given sample of ledger account showing the payment of input credit. ISSUE/ MY
COMPLAINT IS IREO HAS NOT PAID DUTY ON REVERSE CHARGE ON ALL TRANSACTIONS
WHERE PAYMENTS ARE NOT MADE IN 180 DAYS and has reversed on some transactions
only.
S) lreo financial accounting is on SAP software and this duty reversal amount calculation is a
standard report/ query and hence it is surprising that VJ is not able to verify the correctness
& totality. VJ should have attached the SAP report to prove his innocence.
6) Pl find enclosed here calculations for Tax evasions for 180 days ... only for one company i.e
for IREO Pvt Ltd. These details are exactly same as the statutory auditors reports which VJ
has submitted to GST department. As data is voluminous, runs into hundreds of pages, I
enclosed here only first 2 pages . PA- (..,. _ ~ : ,3. 3-: 1 '3 8
7) GST department is already finalising Show Cause Notices(SCNs) to be issued by 30th
September for all five companies audited by VJ for 2018,2019. Those SCNs will prove that
my data/ complaint is true and VJ is making misleading statements.
8) Mr Vinesh Jain in his reply to ICAI is saying that VJ had reasons to believe that payment to
suppliers will be made in subsequent year and VJ did not report, such liability of GST.
9) This is blatantly an illegal statement by Mr Vinesh Jain, knowingly that this is a false statement,
VJ has gone ahead and given a wrong and illegal information to ICAI.
10) Following Questions asked specifically in our complaint remained unanswered.
i) Invoices were raised by companies for all such inter company debits of expenses ?
ii) Was Service Tax were paid on such invoices / debits of expenses by all 21 companies in
2017-18?
iii) Was GST paid on such invoices/ debits of expenses by all 21 companies in 2017-18?
iv) Was GST paid on such invoices/ de bits of e xpenses by all 21 compa nies in 2018-19?
iv) If no invoices raised & NO service tax/ GST paid , why proper disclosures not made by
you in auditor report/ CARO of these 21 companies in 2017-18 ?
v) If no invoices raised & NO service tax/ GST paid , why proper disclosures not made by
you in auditor report/ CARO of these 21 companies in 2018-19 ?
23
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386
,,.....
vi) Have you sought explanation from these 21 companies for not raising invoices/ evasion
of service tax ? If not , please explain why ?
,,.....
,...,_
,,...
........
.,.._
24
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&
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387
CHAPTER 9 --- CHARGE 8

1) Para 9 .4 -- As confirmed by VJ in bank accounts were freezed by Income Tax Dept(ITD) on
25th March 2019 and defreezed on 07.05.2019.
2) lreo did NOT deposit TDS from April 2018 onwards and hence ITD freezed bank accounts.
3) Hence VJ should have disclosed non deposit ofTDS from April 2018 to September 2018 in
the CARO .VJ has avoided disclosures and now trying to argue that in May 2019 these
amounts were paid off.
4) Mr Vinesh Jain's response is evasive and has failed to answer any of the question raised by us
specifically.
5) In roundabout manner VJ is referring his work-steps but has failed to answer non-reporting or
non collection of service tax and timely deposition ofTDS liability.
6) As such his reply is null & void as far as our specific complaint is concerned. VJ is referreing his
work done to the extent IREO group companies has accounted for TDS or Service Tax, if IREO
group companies have evaded tax liability none of the procedure enumerated by Mr Vinesh
Jain explains that. And hence his reply is totally evasive and VJ is admitting gross negligence
done by him.
None of the charges levelle.d by Complainant under charge 9 of our complaint has been replied
by Mr Vinesh Jain.
NON DISCLOSURE OF ATTACHMENT / FREEZING OF BANK ACCOUNTS BY INCOME

TAX DEPARTMENT FOR NON PAYMENT OF TDS MONEY
( 9 a ) Durlng January & February 2019 , Income Tax department has attached bank
accounts of IPL , IW , IGR , IHPL, IRPL companies for non - deposit of TDS deducted by
these companies from April 2018 till December 2019.
.,-.
These bank accounts were attached for almost 15+ days and Income Tax dept collected
almost Rs 30+ crores of TDS and then defreezed these accounts. Can you please explain
why this non payment of TDS for almost 9 months has not been disclosed in the Auditor
report & CARO as on 31st March 2018? I was the informer to the income tax department
in January 2019.
7) VJ has only picked one point about integrity of management and has only stated that
part. It may be noted that such major non-compliance by IREO Group Companies, ,,.....,
needed to be disclosed in CARO specifically. Which Mr Vinesh Jain has failed to do

so. In his reply VJ is totally evasive about such freeze of accounts due to non
deposition of TDS in his audit report.
25
......,
&
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388
CHAPTER 10 --- CHARGE 9

1) The group CFO of lreo Mr. Jai Bharat has been declared PROCLAIMED PERSON (PP) by a
Court. Any and every Indian has a responsibility to Inform police If they find the PP. So as
auditor it Is responsibility of VJ to inform police.
2) Mr Jal Bharat, GCFO of ireo was attending office, has taken full salary for entire year of
2017-18, 2018-19, but police are not able to locate him? This is possible only when lreo
follows a illegal methods/ measures. This issue definitely talks volumes on the legal, ethical
& moral standards of lreo.
3) AT LEAST VJ SHOULD HAVE BROUGHT THE FACT THAT GROUP CFO IS A PROCLAIMED
PERSON ISSUE TO THE NOTICE OF BANKS, HOMEBUYERS, VENDORS BY DISCLOSING THE
SAME IN ANNUAL REPORT.
,....,
......_
26
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389 ,,....,
---..
1) let me explain the FORGED/ BAMANI sale deeds issue in nutshell. VJ is trying to mislead
2) FORGED SALE DEED 5144 SUBMITTED BY GLOBAL ESTATE PARTNERS TO DTCP
a) 5144 with TEHSIL, land is registered in GLOBAL ESTATE, A FIRM
b) 5144 As per Jamabandi (all 3), land is registered in GLOBAL ESTATE PVT LIMITED ,......_
c) 5144 in DTCP License file land is registered in GLOBAL ESTATE PVT LIMITED
d) for 5144, license issued to GLOBAL ESTATE PARTNERSHIP FIRM

---
-..,
e) As per MCA record, GLOBAL ESTATE PRIVATE LIMITED is never registered/ does not exist.
......_
conclusion 2 A - Thus three different departments of Haryana have different & forged sale
......_
deed copies of sale deed 5144
conclusion 2 B -- finally license is issued to a partnership firm which does not own any land at all. ......
conclusion 2 C -- forged sale deed 5144 in the records of DTCP is in the name of a company
which does not exist at all
3) FORGED SALE DEED 14477 SUBMITTED BY GLOBAL ESTATE PARTNERS TO DTCP
a) 14477 , land is registered in GLOBAL ESTATE, A COMPANY
b) License issued to GLOBAL ESTATE PARTNERSHIP FIRM
c) As per MCA record, GLOBAL ESTATE company is never registered/ does not exist.
conclusion 3 A - for sale deed 14477, License is issued to a partnership firm which does not
own any land at all.
conclusion 3 B -- forged sale deed 14477 in the records of DTCP is in the name of a
company which does not exist at all / not registered.
4) OWNERS OF GLOBAL ESTATE PARTNERSHIP FIRM -- La lit Goyal owns 95% and his wife
Sapna Goyal owns 5%. explained in detail below.
5) Para 11.3 .. Rectification Deed ... A rectification signed by four ireo group companies has no
legal sanctity/ legal acceptance. Only a title deed has to be re-registered to correct the
Sale deed. Unfortunately, correction not possible as these sale deeds are forged and In
different departments different copies are available. Also the Rectification deed itself is a
forged document. Also this Rectification Deed is only for one sale deed and NOT for both
sale deeds given above. What happens to the next forged sale deed?
6) Hon CM of Haryana already ordered investigation into these forged saledeeds.

......
27
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390
7) Hon HC of Chandigarh is already seized of this issue.
8) So VJ will realise soon that VJ can not mislead ICAI on this issue and what I have stated in my
complaint is correct and VJ's reply is wrong.
Our Charges were very specific and backed by all evidences.
In para of his reply on page 67, Mr Vinesh jain is talking on behalf of client that Global Estate
Private Limited was an error and not fraud. How can VJ make such comment without giving any
logical conclusion. Land owning in non-existing company can not be an error. VJ is merely saying
" As explained to us". That means VJ has not examined this important aspect of fraud of
,.-..,
construction on Benami Land.
'"'
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,......,_
---,
,...,.,_
28
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391
1) VJ is fully aware of various complaints filed by lreo Investors, by me and even by many ,....
homebuyers. Hence VJ should have been more careful in his disclosures.
2) VJ is aware that sale deed 25202 is a benami land . VJ has been informed clearly about this.
3) But VJ is aware of the PRESENCE OF BENAMI LANDS RAMPANTLY IN IREO GROUP. So VJ
should have disclosed Benami land issues as Title of land is the heart of Real Estate and
Banks, Homebuyers need to be warned of the Benami Lands issue.
4) While responding to charge 11, wherein we have specifically raised the charge that VJ was
....
not the auditor in the year in which the payment was made Precision Realtors Private
Limited. -,.
5) It may be noted for transactions which are continuing in the balance sheet, it is the duty of
the statutory auditor to check the opening balances as per Standard on Auditing notified
under the Companies Act, 2013 and report any mis-statement in those balances.
6) Thus, reply by Mr Vinesh Jain is illegal and evasive.
......
,....,_
29
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392
1) VJ failed to report default of PNBHFL loan Principal repayment amount by lreo Private
Limited.
2) VJ has NOT given any explanation why VJ failed to disclose. VJ tried to justify that VJ has
disclosed default of interest amount .
3) If there is no default of payment of Principal amount, PNBHFL would not have attached
27 acres of land under SARFAESI.
4) VJ did not verify loan repayments defaults and blindly signed annual reports.
5) Finally, VJ failed to disclose DEFAULT OF PRICIPAL AMOUNT REPAYMENT by lreo Private
Ltd.
6) The fact is that PNB Housing has taken over the assets of the Company. This fact of non
,-
reporting of default was therefore established.
7) Mr Vinesh Jain's reply referring to his work paper can not undermine the fact that there
was violation of payment which resulted take over of land and VJ failed to report the ......,
same.
30
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393 ......
,......_
Para 14.3.4 ...
1) VJ admits that he has reported that RERA application of lreo Residences Project is pending as
on 31st March 2019.
2) But RERA has rejected registration in December 2017 itself
3) RERA only updates approved projects information on the RERA website. RERA website does
not disclose details of what applications are pending and what applications are rejected. VJ
is just trying to justify his "hand in glove" approach.
4) I have collected REJECTION PAPERS THROUGH RTI from HARERA.
5) CONCLUSION 13 .... VJ MADE A WRONG DISCLOSURE THAT GRAND HYATT PROJECT
REGISTRATION IS PENDING WITH RERA.
6) The note which VJ is referring has been given by the management, auditor's reliance on the
note or disclosure by management cannot obviate himself from his professional duty.
7) Even if management has disclosed that application is pending, Mr Vinesh Jain is agreeing that
there was significant uncertainty as application is pending for more than 2.5 years.
8) VJ failed to put an emphasis of matter/ modification in audit report as per SA 705 & 706. It is
to be noted if there was such a material uncertainty which can bring the closure of the project,
it should have been put in the auditor's report as emphasis of matter.
9) Google search etc are absurd. Working papers VJ is referring to conceal his fraudulent
reporting, merely relying on management or even collusion with the management on such
important matter.
10) VJ has further written that VJ merely discussed with the management and relied that no such
rejection has taken place. Discussion is not an appropriate audit procedure when such a
significant uncertainty over project for violation of law exists. Management will never tell his
that project has been rejected by authorities. Its an absurd reply by VJ and not acceptable
reply by Mr Vinesh jain.
,-..
.......
-..
31
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394
,,........
1) Each apartment is sold at Rs 15 crores to Rs 30 crores because it is branded "GRAND HYATT
APARTMENTS". '""
2) Apartment Buyer Agreement (ABA) clearly states that company has signed three agreements
with Hyatt International .... (a)Branding, (b)Technical services, (c)maintenance agreement
3) If there is no GRAND HYATT brand name, then this apartment is like any other project and
price will reduce drastically. HENCE DISCLOSURE OF CANCELLATION OF AGREEMENT IS
EXTREMELY IMPORTANT.
4) As per agreement with Hyatt, IRCPL has to pay 4% as the branding fees from the amount
IRCPL collects from homebuyers. As confirmed by VJ in para 15.5.2, no payments were made
to Grand Hyatt in 2017-18 and 2018-19. But in these 2 years, IRCPL collected more than Rs
150 crores from homebuyers, but IRCPL has neither made provision for paying 4% nor paid
4% to Hyatt international. As auditor VJ should have investigated and reported properly
about the cancellation of agreement of Hyatt International agreement.
CONCLUSION - VJ FAILED TO DISCLOSE THE CANCELLATION OF HYATT INTERNATIONAL
AGREEMENTS IN THE GRAND HYATT RESIDENCES PROJECT
,......,_
.......
......
.---..
......
32
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395
1) As per GST returns filed for Grand Hyatt Residences Project, the input taken on materials by
IRCPL is only Rs .... for 2 years of 2017 to 2019. Data is given below. Only structure
construction going on at site as confirmed by VJ in clause 16.3.5 and both cement & steel
used for construction of structure have a GST rate of 18%. So materials cost can not be
more than Rs .... for 2 years of 2017-2019. So how Rs 70 crores materials cost accounted by
IRCPL?
,2017 OctillMt, 2011 ,.__,21117 DIMlll«,ztl1 1t11 . lOU Mlrdt.Jtll T_.
• 17 M,tll
.-....--.-..... __. .......... .._... .....a.4..........,,..... --- ..............
,1t,N S !OM.707 S.JUH 1,.IW,IM U4.J 40I 1.Mm 2"
~
lr>J0,,.,121
.._....
1:--~--
:.r...:;.:.-r:s--.. . 1,,..;;,- . I.;;,.,;'!~;..-I "'~..1uijffi'ft.1-l m::,.l ..."'oo"..;1.,1 um-:Sr.J d;i".::;..,I ..:.w-:...1,41::..1 .......:r......1
2) So on a 9 crores net input credit how can a materials cost of 72 crores can be justified?. By
reverse calculation of 18% GST, Cement & Steel purchases of only Rs 45 crores can
justified. Rs 72 crores can not be justified.
3) So the amount spent on construction materials of Rs 59 crores for 2017-18 and Rs 21
crores for 2018-19 is nothing but accounting of bills of some other project OR fudged/
forged bills.
4) As auditors are hand in glove with lreo management, they allowed all sorts of wrong
accounting.
5) Also Zoning plans, building plans of Grand Hyatt Residences project WERE CANCELLED BY
DTCP ON 09TH DECEMBER 2015. So any construction at the site is illegal for Grand Hyatt
Residences.
.......
......
.......,
,,...
......
33 ........
........
....
&
TRUE COPY
396
1) One of the fundamental rules of audit is "SUBSTANCE OVER FORM"

2) Read the entire contract of IPL- HERITAGE MAX contract. It is clearly for the sale of
DEVELOPMENT RIGHTS along with land .
3) Not only that clauses 6.1 to 6.6 of the agreement clearly states that Haryana Government
Permission under BIP(Beneficial Interest Policy)is required and if BIP policy approval is not
given, agreement gets terminated. ( given below)
4) Purpose of BIP policy is clearly stated ... If Licensed land is with one company and if any
other company wants to use that License, or market etc ... then BIP approval is must.
5) BIP approval letters clearly states that once approval is given even BUILDING PLANS
APPROVED EARLIER IN LICENSEE NAME GETS TRANSFERRED TO HERITAGE MAX. In other
,-..
words, in the eyes of Haryana Government, the Development Rights got transferred
irrevocably to Heritage Max and nobody can challenge this statement.
6) Even RERA approvals are in the name of Heritage Max
7) So when Haryana Govt recognises Heritage as new owner + when regulator RERA
recognises Heritage Max , then there is NO reason / logic for auditors not to recognise
sale of development rights & revenue. Auditors can not go simple by the form of the
agreement, they need to see the substance/ underlying transaction.
8) Hence Revenue is recognisable by IPL when Haryana DTCP gave sanction letter under BIP.
9) As VJ is In hand in glove with the management in the evasion of income tax & GST, VJ has
helped ireo by not recognising the revenue.
10) The reply by Mr Vinesh Jain is evasive. VJ has not given any answer why revenue recognition
criteria were not met. We in our complaint has given full evidences and detailed reasons.
11) Thus, Mr Vinesh Jain has failed to respond to charge 16 and give any valid reason why revenue
was not recognised, and/or evasion of service tax/ Income Tax, payable on that revenue. ......,_
12)Merely saying that revenue was not recognised can not be a valid reply at all by a Chartered
Accountant.
I CHANG! IN BENEFICIAL WTEREST

e.1 nwt 1t1e GcNerm,ent of ~ t1a nolfted • po11cy vlde ·na.PF-61N2015t2708 dlllild
18.02.2016 tltled u · ~ Patametera ~ alOwtlg C/llflOI In Bl#'lfllcllll ,,__ vtz. Ching,
ii DfNelop«; ~ d J o i n t ~ rlghlaandbt'~ Rlg#Q. a In a lk:etlae
granlMl underAd no.8 d 1f115' (the "Change In Beneflclal bdllrat Polley").
8.2 . IREO and HMRPL (and Land OWnn r requr9d u n d e r ~ Lawa) ahall rNM • raques:
ID OTCP for grant d permilllon for carytng on dlllllcpnel'lt CMr 1tle Cdlllbcnllon LM1d end
Culabo,alorl FAR. • eat out In thla At,w.11111t. It, -x.adllnee with the Cla,oe In a.lllflcla!
,,,..,.. Polbf. .
e.a Upon mmlndon of 1t1e Nici requeet by the DTCP, HMRPL and IREO 1h11 comply wllh h
Nqijiamentl u may a» p,9la1bed by the 0TCP Ir, -.cordalioe with P.-a 4.1 d the ~ lo
Benelldal lfMNlt POiley OI· othelwlle, In the NlfflN of HMRPL and IREO, to the .-nl
applicable to Nd'I ofthem. HMRPL 1h11 be 1'91ponalble to t»ar the' 'admlttllltl ...... ct,qell' and
the ltlddental c:Clla ~ ~ - • may be mutudy agreed for the Cc:lllilbcatlon Land I
""'
34
&
TRUE COPY
397
,,...._
CHAPTER 18 - CHARGE 17 ,....._
1) Para 18.3.3 & also Para 18.4.9 --- it is blatant lie that project is not launched and no sales
happened ..... Reality is even OCCUPATION CERTIFICATE has been issued already in
February 2019 Itself. More than 70% of the apartments are already sold off.
Balance sheet of Watsonia developers ( RENAMED AS Mahindra homes )enclosed here as a
proof. p ~G... ir5 : j ~ f.,. 0 J, ( fo- "1 2---
Even lreo has sold five of apartments ~llocated'to it from this project as per the GST returns
filed.
2) One of the fundamental rules of audit is "SUBSTANCE OVER FORM"
3) Read the entire contract of IPL-WATSONIA contract. It is for the sale of DEVELOPMENT
RIGHTS and Land.
4) Watsonia applied for Occupation Certificate and DTCP has refused to issue OC unless BIP is
done.
5) Purpose of BIP policy is clearly stated ... If Licensed land is with one company and if any
other company wants to use that License , or market etc ... then BIP approval is must. ,.....
6) BIP approval letters clearly states that once approval is given even BUILDING PLANS
APPROVED EARLIER IN LICENSEE NAME GETS TRANSFERRED TO WATSON IA. In other words,
in the eyes of Haryana Government, the Development Rights got transferred Irrevocably
to WATSONIA and nobody can challenge this statement.
7) Auditors can not go simply by the form of the agreement, they need to see the substance/
underlying transaction.
8) Hence Revenue is recognisable by IPL when Haryana DTCP gave sanction letter under BIP.
9) As VJ is in hand in glove with the management in the evasion of income tax & GST, VJ has
helped ireo by not recognising the revenue.
10) The reply by Mr Vinesh Jain is evasive. VJ has not given any answer why revenue recognition
criteria were not met. We in our complaint has given full evidences and detailed reasons.
11) Thus, MrVinesh Jain has failed to respond to charge 17 and give any valid reason why revenue
--..
was not recognised, and/or evasion of service tax/ Income Tax, payable on that revenue.
12) Merely saying that revenue was not recognised can not be a valid reply at all by a Chartered
Accountant.
"
35
,-..
&
TRUE COPY
398
--
Project wise cenvat credit details till March 31,2015
Sum of Balance Column Labels

Row Labels 2012-2013 2013-2014 2014-2015 Grand Total
Brokerage 86,70,077 3,58,95,054 1,21,97,518 5,67,62,649
Club-GA 61,800 10,702 72,502
Common 5,41,44,766 3,36,47,285 7,14,65,455 15,92,57,506
MA ~ 4.1826001 4,68.8'- R4'- 4,97.27.Rf..9 11lR4,39,716
Gurgaon Commercial -Sec-65 (13.08 Acres) 18,47,009 79,042 19,26,051
Gurgaon Group Housing-Sec-61 (19.43) Acres) 3,90,581 8.69.740 36,81,280 49,41,601 f - - -
--
ICC 38,20,494 8,54,407 53,35,389 1,00,10,289
ICP (6,97.136) 12,175 47,146 (6,37,816)
IGH 6,53,364 84,03,905 3,70,11,717 4,60,68,986
lreo-City 80,58,655 64,52,080 1,45,10,734
IREO-FLOORS 11,53,327 8,47,661 20,00,988
Skyon 2,65,83,076 4,64,04,864 5,50,50,692 12,80,38,633
University 2,52,01 3 0 2,52,013
Uptown 2,07,36,008 1,76,34,078 1,74,41,567 5,58,11,653
Villa 8,24,082 1,70,997 9,95,079
Grand Total 15,82,26,253 20,07,84,258 25,94,40,073
- 61,84,50,585
I
C ~
£rand Arch -
-----
- __.)
2 012-2013
4,18,26,001
2013-2014
4,68,85,845
2014-2015
4,97,27,869
2015-2016 TOTAL
Common Ratio 31% 31% 28%

Common Credit 1,67,84,878 1.04,30.658 2,00,10,327
-- -
Total Credit 5,86,10,879 5,73,16,504 6,97,38,196 6,00,00,000 24,56,65,579
I OC
-- - 18-09-2014
--
II OC-17-12-2015
Saleable Area-GA 17,60,875
,__.__
Unsold Area- as -
on Dec 15
-- 3,39,511
%age Unsold Area 20% 20% 20% 20%
~rsal of Credit 1,17,22,176 1,14,63,301 1,39 47,639 1,20,00,000 4,91,33,116

Interest 84,39,967 55,02,384 33,47,433 28,80,000 2,01,69, 784
Total Payable
-- ./ 2,01,62,142 1,69,65,685 1,72,95,073
REVERSAL PER SFT Rs.
1,48,80,000 6,93,02,900
204.13
Average Sale Price ----- 7,000
2,37,65,77,000
8,000
2,71,60,88,000
9,000
3,05,55,99,000
10,000
3,39,51,10,000 -
Sale Value - -
Service Tax Rate
---- ·- 4.5% 4.5% 4.5~ - 4~~
-- - -
Service Tax Paya~ __ 10,69,45,965 12,22,23,960 13,75,01,955 15,27,79,9~ _
~ ble Area-Uptow~
u nsc,m Hrea as on Dec 15
10,58,951
1,17,336
- -
o/oage Unsold Area 12% 12% 12% 12%
--
Uptown
-- - - --- 2,07,36,008 1,76,34,078 - ~ .41,567 ,......,_
Common Ratio 8% 9% 8%
~ nCredit 43,31,581 30.~8.256 _ _ 57,17,236 _
2,50,6 7,589 2,06,62,333 2,31,58,804
-- - - ->----8,88,88,726
2,00,00,000
Total Credit
--
Reversal of Credit
-- - -
30,08,111 24,79,480 27,79,056 24,00,000 1,06,66,647
Interest 21,65,840 11,90,150 6,66,974 5,76,000 45,98,964
Total Payable - ') 51,73,950 36,69,630 34,46,030 29,76,000 1,52,65,611 ,..._
~ -- REVERSAL PER SFT 130.10
7000
Avera11e Sale Price
Sale Value
4,000 t-
46,93,44,000
5000
J B.66,BJ),000
- - 6000
70,40,16,000 82,13,52,000
- --
- --
Service Tax Rate 4.5% 4.5% 4.5% 4.5%
Service Tax Payable 2,11,20,480 2,64,00,600 3,16,80,720 3,69,60,840
......
& 3 {,
TRUE COPY
~
·"'
IPL - lnvoices- Vendon -201>19 IPL - ln"'Oic:t:s-Vendo (PL - Invoices · Vendon - 201S. t9 IPL - ID•oices- v..4on - 201s.1, 399
au,_. ae,·tna1 Out Rnffl&I fle.Cmlil
Fisc:al Orl/Ac<t Profi t Cen1cr CENVAT Do<- Clearanc:e Credit DIiie Actual Datt Dalt
Yr CoCodc OocumcntNo Psq Oak Enuy Date Doc. Dale Tn,c Cwrency s G'L. Name Vend« Vendor - P.,cl,.Doc. Amouc Jilatcol'Tu St:nitt Tu u.c... SBEC... KXC o... T ...... O..C
Ol -04-201l ( 1,46,303) 12.36% (1,42.042) (2,84 1) ( 1,420) 2200001674 04-A.pr- l S Ol•Apr•ll 30-06-201!
2016 2000 100022219 31--03-2017 03-04-2017 3 1--07-2015 AB JNR. OCOA 10652 $1.-yoo 120000062 VADEHRA BUILDERS p, (S.98,449) IS% (ll.67,468) (30,981) 182204473 16-Ju-l& JI-M•-17 29-10-2015 29--I0-20U 16-Jm-18
2016 2000 100022219 ll-03-2017 03-04-2017 3 1--07-2015 AB 1NR OCOA 1436.52 Sl")l>ft 1 20000062 VADEHRA BUILDERS P' 8.27,747 IS% 7.99.204 28.543 182204473 16-Jao-1 8 3I-Mar-17 29,10-2015 29-I0-201S 16-1•·18
2016 2000 100022279 31--03-20 17 05-04-20 17 04-03-2016 AB (NR OCOA 143652 Oura,aon Hillt 120000301 GREEN FACADE sourr (S3.303) 15% (51.465) (1.838) 192200161 04-May-18 3I-Mar-17 02-06-2016 02-06-2016 04-May-18
2016 2000 100022280 3 1-03-2017 OS-04-2017 29-12-201S AB INR OCOA 1◄3652 Cupoo Hilb 120000301 GREEN FACADE SOI.UT 5S,Jl59 15% 53,933 1.926 192200l61 04-Moy-18 3I -M ••J7 28-03-2016 28-03-2016 04-May-18
2016 2000 I 00022280 31-03-2017 05-04,2017 29-12-2015 AB INR OCOA 1◄3652 Gurgaoo Hilu 120000301 GREEN FACADE SOI.UT (73, 16l) 1.5% (70,642) (2,523) 192200861 04-May-18 31-M ar-17 28-03-2016 28-03-2016 04-May-18
2016 2000 I 00022297 31-03-2017 05-04-20 17 ~2015 AB 1NR OCOA 1◄36S2 M.._i Sen 120000SIO JAJ JAJ RAM SINGH INFI (39,392) 15% (38,034) (1.358) 100022376 31 -M•-17 3I-M •-17 2 1-09-201l 21-09-201S 31-Ma--17
2016 2000 I 00022301 31-03-2017 05-04-20 17 05-02-2016 AB INR OCOA 143652 Mm&&<d Sen 100001012 SHANNON &SHANNON (9,873) 15% (9,S32) (341) 180101042 21-Jun-1 7 31-M•-17 05-05-2016 Ol-Ol-2016 2I-Jun-17
2016 2000 100022371 31--03-2017 12-04-2017 3 1-03-2017 AB JNR OCOA 1◄36S2 Manaecd Sen 120000510 JAJ JAi RAM SINGH JNFI (58,526) 15% (56.508) (2,018) 100023842 3I-M•- 17 3 1-M•-I 7 29-06,2017
2016 2000 I 00023246 31--03-2017 24-04-20 17 OS-02-201Ci AB JNR. OCOA 143652 M lnq<d Sen 100001012 SHANNON &SHANNON (19.9'l) 15% (19.267) (688) 180101042 21-Jun-17 3l•M•-17 OS-05-2016 OS-OS-2016 21-Jun-I7
1016 2000 100023261 31-03-2017 25-04-2017 3 1-03-2017 AB INR OCOA 1436S2 IREO Grand , 120001210 ZIM WORLD FR EIGHT P (4,209) 15% (◄.064) ( 145)100023268 3 1-Mw-17 3I -M••l 7 29-06-2017
2016 2000 I 00023261 31-03-2017 25-04-2017 31-03-2017 AB INR OCOA 143659 IREO Gnnd , 120001210 ZIM WORLDFREIGHTP (ISO) IS% (145) (5)
100023268 31-M •-17 31-Mar-17 29-06-2017
2016 2000 I 00023593 31-03-2017 25-04-2017 27-05-2015 AB INR OCOA 143652 Gurpon Hilb 120000079 11..tFS ENGINEERING Al (29,023) 15% (28,022) (1.001) 192200370 09-May-18 31-Ma,•17 2S-08-201S 25-08-2015 09-May-18
2016 2000 100023593 31-03-2017 25-04-2017 27-0S-201l AB INR OCOA l4)6j2 W'pon Hill! 120000079 11..tFS EIIGINEElllNG Al (22.S76) 15% (21,798) (778) 192200370 09-May·-18 J I-Mar-17 2l-08-201S 25-08-2015 09-May-18
2016 2000 100023593 31-03-2017 25-04-2017 27-05-201l AB INR OCOA 1436l2 Gurgaoo Hill, 120000079 11..tFS ENGINEERING Al (452) IS% (◄36) ( 16)
192200370 ()9.May-1 8 31-Mar-17 25-08-2015 2S-08-201l 09-May-18
2016 2000 I 00023593 31-03-2017 25-04-2017 27-05-2015 AB INR OCOA 1◄36l2 Gurpoo Hill, 120000079 11..tFS ENGINEERING Al (226) (218) (ll)
192200370 09-May-18 31-Mar-17
2016
2016
2000
2000
I 00023595
100023595
31-03-2017
31-03-2017
25-04-2017
25-04-2017
27-0l-201l
27-05-201l
AB INR
AB INR
OCOA
OCOA
1436l2 Gurpoo Hill,
143652 Gurp:,n Hilb
120000079 11..tFS ENGINEERING Al
120000079 11..tFS ENGINEERING Al
(IOI)
(200)
""
15%
15%
(101)
(202)
(◄) 192200370
(7) 192200370
()9.May•-18
()9.May·-18
3I-Mar-17
31-Mar- I7
2l-08-201S
2S-08-2015
25-08-2015
25-08-201l
2l-08-201l
25-08-201l
()9.May-18
()9.May-18
09-May-18
2016 2000 I 00023595 31-03-2017 25-04-2017 27-0l-201l AB 1NR OCOA 143652 Gtrpoo Hilh 120000079 11..tFS ENGINEERJNG Al (10,452) IS% (10,002) (360) 192200370 09-May-18 31-M•-17 2l-08-201S 2S-08-201l 09-May- 18
2016 2000 I 00023595 3 1-03-2017 2l-04-2017 27-0l-201l AB INR OCOA 143652 Gut-pon Hill~ 120000079 11..tFS ENGINEERING Al (13.437) 15% ( 12,974) (463) 192200370 09-M•y-18 31-Mar-I7 2S-08-2015 25-08-201l 09-May,18
2016 2000 I 00023597 3 1-03-2017 25-04-2017 14-11-201l AB 1NR OCOA 143652 Ourt;IOl'l Hilb 120000079 11..tFS ENGINEERJNG Al ( 1,36.836) 15% ( 1,32.118) (◄.718) 20220082◄ 16-Jul-19 :31-Mar-17 12-02-2016 12-02-2016 16-JuJ.19
2016 2000 100023599 3 1-03-2017 25-04-2017 14-11-201l AB 1NR OCOA 143652 Gurpon Hilb 120000079 11..tFS ENGINEERING Al (1.00,170) IS% (%.716) (3.454) 3 I -M •-17 12-02-2016 12-02-2016
2016 2000 I 00023850 31-03-2017 27-04-2017 06-11-lOll AB INR OCOA "3652 $1.-yon 120000000 JJOJ CONSlltUCTIONS f 9,050 IS% 8,738 312 180100371 27-Ap,-17 :31-M•-17 04-02-2016 04-02-2016 27-Ap,- 17
2016 2000 I 00023850 31-03-2017 27-04-2017 06-11-2015 AB 1NR OCOA 14J6ll Styon 120000000 JJDJ CONSntUCTIONS f (66.30◄) 15% (6◄,017) (2.287) 180100371 27-Ap,-17 3I -Mar-I7 04-02-2016 04-02-2016 27-Ap,-17
2016 2000 100024019 31-03-2017 28-04-2017 14-12-2015 AB INR OCOA 143652 S ECTOR-59 1 30000◄58 MJ.ENGINEERJNG CON: (1,505) IS% ( l,◄53) (52) 31-M.--I7 1)-03-2016 13-03-2016
2016 2000 I 00024026 31-03-2017 28-04-2017 14-12-lOIS AB INR OCOA 1436l2 I REO PVT L' 130000236 AECOM INDIA PRIVATE ( 1,05,000) 15% (1,01.379) (J.621) 10002-!026 Jl•M •-17 ll•M••l7 13-03,2016 13-03-2016 3 I-M•-17
2016 2000 100024032 31-03-2017 28-04-2017 31-03-2017 AB INR OCOA 143653 M.,...od Sen 100002m GRlHA COUNCIL (ll4 ,000) 1.5% (11_103) (l.897) I 0002◄032 31-M•-17 3 I -Mar-I 7 29-06-2017
2016 2000 100024032 31-03-2017 28-04-2017 31-03-2017 AB INR OCOA 143658 M.,....S Sen 100002m GRJHACOUNCIL (J.000) 15% (2,897) (103) 10002<032 ll.M.--17 Jl-Mu-17 29-06-2017
2016 2000 I 00024038 31-03-2017 28-04-2017 31-03,2017 AB 1NR OCOA 1436'9 S~")'Ol'I 1200012S4 INDUSCONTAINERLIN (78) l .5'Y. (75) ()) I 00024038 31-M•-17 :31-Mu -17 29-06-2017
2016 2000 100024038 31-03-2017 28-04-2017 31-03-2017 AB INR OCOA 1<3652 Sl.')00 120001254 INDUSCONTAINERLIN (2, 176) 15% (2,101) (7l) I 00024038 31-.M•-17 :31-Mu-17 29-06-2017
2016 2000 100024211 31-03-2017 18-08-2017 31-03-2017 AB INR OCOA 143659 IREO PVT L' 120000035 NEWAGE LMNG sour 82,400 15% 79,559 2,841 100024211 31-M•-17 3 1-Mar-I 7 29-06-2017
2016 2000 100024211 31-03-2017 18-08-2017 3 1-03-2017 AB INR OCOA 143652 IREO PVT L' 12000003S NEWAGE UVJNG sour 23.07.200 IS% 22.27,641 79,5S9 100024211 3I-M•-17 3 1-Mar-l ? 29-06-2017
2016 2000 10002-4211 31-03-2017 18-08-2017 31-03-2017 AB JNR OCOA 1◄3659 IREO PVT L' 120000035 NEWAGE UVINGSOUT (82.◄00) 15% (79..S59) (l.841 ) 100024211 3I-Mar-I 7 :3 1-Mar-17 29-06-2017
2016 2000 100024211 31-03-2017 '18-08·2017 31-03-2017 AB INR OCOA 1◄3652 I REO PVT L" 120000035 NEWAGE UVING SOUi' (23,07.200) 151/. (22.27.6◄ 1) (79.ll9) 100024211 3 I -Mar-l 7 3 I-Mar-17 29-06-2017
2016 2000 2100005422 31-03-2017 31-03-2017 16-02,2017 KR 0-'R OCOA 143658 Man,gcd Sen 120000272 COLLEcnONS 13 15% 12 I 11220092<' 02-Jian-I 7 3 1-Mu - 17 17-0S-2017 17-0l-2017 02-1 ...-11
2016 2000 2100005422 31-03-2017 31-03-2017 16-02-2017 KR INR OCOA 1◄36S3 Man,gcd Sen 120000272 COLLEcnONS 355 15% 343 12 182200924 02-Jun-17 31-Mat- 17 l7.0S-2017 17-0S-2017 02-Jun-17
2016 2000 2100005424 31--03-2017 31--03-2017 16-02-2017 KR INR OCOA 1◄3658 Skya, 120000272 COU.ECTIONS 26 15% 25 I I 82.2 00924 02-Jun,.I7 3 1-Mar-17 17--05-2017 17--0S-2017 02-J&m-17
2016 2000 210000542◄ 31--03-2017 31-03-2017 16-02-2017 KR 1NR OCOA 1◄3653 SL')<ft 120000272 COLLECTIONS 734 15% 709 2l I 82200924 02-fon- I 7 :31-M.-- 17 17-05-2017 I7-0S-20I7 02-Jll'l-17
2016 2000 2100005425 31-03-2017 31-03-2017 16-02-2017 KR INR OCOA 143653 Gu-pon Hilh 120000272 COLLEcnONS 42 1 15% 407 14 182200924 02-J1m-l 7 31-M•-17 17-05-2017 17-05-2017 02-Jun-17
2016 2000 2 100005425 31-03-2017 31-03-2017 16-02-2017 KR INR OCOA 1◄36l8Gu,_, H,lli 120000212 COLLEcnONs ll I S% 15 0 182200924 02-Juo-17 31-Ma<,17 17-05-2017 17-05-2017 02-J .... l7
2016 2000 2100005485 31-03-2017 06-04,2017 28-02,2017 KR INR OCOA 1436l9 IREO PVT L' 120000169 SHARP BUSINESS SYSTI 3 1w. 3 0 1822009'6 02•JWl- l 7 31·Mar•l 7 29--05-2017 29-05-2017 02-Jun- 17
2016 2000 2100005485 31-03-2017 06-04-2017 28-02-2017 KR INR OCOA 143652 IRfO PVT L' 120000169 SHARP BUSINESS SYSTI · 89 15% 86 3 182200956 02-Jua-17 31-Ma,,17 29-0S,2017 29-05-201 7 02-Jun-17
2016 2000 2100005492 31-03-2017 06-04-2017 29-03,2017 KR 1NR OCOA 1436l2 IREO PVT L' 130000254 JAIN J INDAL & CO 1,680 15% 1,622 58 182200154 10-Ap,-17 ll-Mar-17 2 7-06-2017
2016 2000 2100005492 3 1-03-20 17 06-04-2017 29-03-2017 KR INR OCOA 143659 IREO PVT L. 130000254 JAIN J INDAL & CO 60 15% 51 2 182200154 10-Ap,-17 31-Mar-I7 27-06-2017
2016 2000 2100005507 31-03-2017 07-04-2017 28-02-2017 KR INR OCOA 1436l2 SL)-on 120000169 SHARP BUSINESS SYSTI 3SS U¾ 342 13 182200956 02-Ju- 17 :3 l•M&r•l7 29-05-2017 29-05-2017 02-J ..,.17
2016 2000 2100005507 3 1-03-2017 07-04-2017 28-02-2017 KR INR OCOA 143659 Sk)-on 120000169 SHARPBUSINESSSYST I 13 IS¾ 12 I 182200956 02-Jua- 17 3 1-Mar-I7 29-0S-2017 29-05-2017 02·1""•17
2016 2000 2100005522 31-03-2017 10-04-2017 31-03-2017 KR 1NR OCOA 143652 IREO Gnnd, 13000002< MAlltA ARCHITECTS & 70,000 15% 67,586 2.41◄ 182200133 10-Ap--17 3 1-Mar-I7 29-06-2017
2016 2000 2100005522 3 1-03-2017 10-04-2017 31-03-2017 KR INR OCO A 143659 IREO Grand , 130000024 MATRAARCHITECTS& 2,500 IS'Ye 2,414 86 182200133 10-Ap,-17 31-Mar-17 29-06-20 17
2016 2000 2100005524 31-03-20 17 11-04-2017 31-03-201 7 KR INR OCOA 143659 IREO PVT L' 130000269 VUAY RAJ& CO. 180 ll% 17◄ 6 182200412 26-Ap,-17 3 1-M.,,17 29-06-2017
2016 2000 2100005524 31-03-2017 11-04-2017 31-03-2017 KR INR OCO A 143652 IREO PVT L' 130000269 VUAY RAJ & CO. S.040 ll% 4,866 174 182200412 26-Ap,-17 3 1-M•-17 29-06-2017
2016 2000 210000553 I 3 1-03-2017 11-0◄ ,20 17 16-03-2017 KR INR OCO A 1436S3 IREO PVT L' 120000272 COLLECTIONS 36 IS% 35 I 182200924 02., ...... 11 l l •M-- 17 14-06-2017
2016 2000 2100005531 3 1-03-2017 11-04-2017 16-03-2017 KR INR OCOA 143658 IREOPVTL' 120000272 COLLECTIONS 15% I 0 18220092◄ 02-JI.Wt-l7 3 1- --17 14 -06-2017
2016 2000 2100005532 3 1-03-2017 11--04-2017 16-03-2017 KR INR OCOA 143653 IREO PVT L' 120000272 COLLECTIONS 476 IS% 460 16 182200924 02-hm-l7 :3 1-M•- 17 14-06-2017
2016 2000 2 100005532 3 1-03-2017 11-04-2017 16-03-2017 KR 1NR OCOA 143658 IREO PVT t· 120000272 COLLECTIONS 17 15% 16 I 11220092◄ 02-J1111-l 7 3 1-M•- 17 14-06-2017
2016 2000 2 100005533 31-03-2017 11-04-2017 16-03-2017 KR INR OCOA 143658 IREO PVT L' 120000272 COLLECTIONS 6 IS% 6 (0) 182200924 02-Jun-l 7 3 1-M.--17 l◄-06-2017
2016 2000 2100005533 31-03-2017 11-04-2017 16-03-2017 KR INR OCOA 143653 IREO PVT L' 120000272 COLLECTIONS 161 IS% 156 l 112200924 02-J--17 J l-M•-17 14-06-2017
2016 2000 21 00005ll◄ 31--03-2017 12-04,-20 17 28-00-2017 KR INR OCOA 143659 IREO PVT L' 130000254 JAIN JINDAL & CO 113 15% 109 ◄ 182200222 13-Ap,-17 Jl-M•- 17 26-06,2017
2016 2000 21 OOOOSll◄ 31-03-2017 12-04-2017 28-03-2017 KR 1NR OCOA 143652 I RE0 PVT L' 130000254 JAIN JINDAL & CO 3.150 ll% 3,041 I09 182200222 13-Ap,-17 3 1-M., 17 26-06-2017
2016 2000 2100005560 3 1-03-2017 13-04-2017 27-03,2017 KR JNR OCOA 143652 I REO PVT L' 100000227 KYOCERADOCUMENT 89 15% 86 3 1822010!7 06-Jm- 17 :3 I-Ma-- 17 25-06,2017
2016 2000 2 100005560 31-03-2017 13-04-2017 27-03•2017 KR INR OCOA 143659 I REO PVT L' 100000227 KYOCERA DOCUMENT . 3 15% 3 0 1822010!7 06-JIID-l 7 Jl-Mar-17 ll-06-2017
2016 2000 2 100005571 3 1-03-2017 13-04-2017 31-01·2017 KR INR OCOA 1436S2 M...aa,d Sen 120001012 V INSPIRER FAOUTY ~ 357 IS% 34S 12 182203201 27.0C.-17 J l-M•-17 0 1-05-2017 0 1-05-2017 27-0:,-17
2016 2000 2100005571 3 1-03-2017 13-04,2017 3 1-01-2017 KR INR OCOA 143659 Mm&&<d Sen 120001012 V INSPIRER FACILITY ~ 13 IS% 12 I 182203208 27.0C.-17 31-Mar- 17 OI-Ol-2017 0 1-05,2017 27-0:,,17
2016 2000 2 100005572 31-03-2017 13-04-2017 31-01·2017 KR INR OCOA I 0652 I R.EO C1ty Pl, 120001012 V INSPIRER FAOUTY ~ 231 15% 23-0 8 182203201 27.0C.-17 3 I-M•- 17 0 1-05-2017 01-0l-2017 27-0:,-17
2016 2000 2100005572 31-03-2017 13-04-2017 31-01-2017 KR INR OCOA 1◄3659 I REO City Pl, 120001012 V INSPIRER FACILITY~ 9 15% 8 I 182203208 27.0C.-17 3I-Mw- l 7 01-05-2017 01-05,2017 27-0a-17
) L~2017 KR INR
~
2016 2000 2100005S79 31-03-2017 17-04-2017 OCOA 1◄36S8 IREO PVT L' 120000272 COLLECTIONS 9' IS% 92 3 182200924 02-Jua-17 l l •M•- 17 29-06-2017
2016 2000 2100005579 3 1-03-2017 17-04-2017 31-03-2017 KR INR OCOA 1◄36l3 I REO PVT L' 120000m COLLECTIONS 2.660 IS% 2.568 92 182200924 02..Jua-l7 3 1-Mar- 17 29-06-2017
2016 2000 21 0000ll92 3 1-03-201 7 13-04-2017 0 1- 11-2014 KR rNR OCOA 1◄36l2 IREO PVT t· 130000254 JAINJINDAL&CO 2,400 U% 2.317 SJ 182200251 17-Ap,- 17 3 1-Mar-17 30-01-201l 30-0l•lOll 17-Ap,•1 7
i
2016 2000 2100005592 3 1-03-2017 13~·2017 01- 11-201-4 KR. lNR oco;. 143652 IREO PVT L' 13000025◄ JAINJINDAL&CO 24 15% 23 I 1822002ll 17-Ap,-17 3 1-Mar-17 30-01,2015 30-01,lOIS 17-Ap,-17
2016 2000 21 00005S92 3 1-03-2017 13--04-2017 0 1-11-2014 KR INR OCOA 1◄3652 IREO PVT L' 13000025◄ JAIN JINDAL & CO 48 IS% 46 2 182200251 l 7-Ap,-17 3 1-MN-17 30-01-2015 JO-Ot.201l 17-Ap,-17
2016 2000 2100005595 3 1-03-2017 17-04-2017 3 1-08-2016 KR fllR OCOA 143652 IREO PVT L' 120001170 KONICA MINOLTA BUSI 86 15% 13 3 182203503 11.-.- 11 31-M.--17 29-11,2016 29- 11-2016 l 7-N°'·-17
2016 2000 2100005595 3 1-0J.2017 17-04-2017 3 1-08-2016 KR INR OCOA 1◄3659 IREO PVT L' 120001170 KONICA MINOLTA BUSI 3 15% 3 0 18220)503 11.-.- 11 31-Mar-I7 29-11·20l6 29·11·20 16 17-Nov•l7
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2016 2000 2100005596 31-03-2017 17-0<-20 17 30-06-2016 KR INR OCOA 143652 Skyao 120001170
KONICA ~DNOLTABUSI 154 1m 149 182203503 17-Nov-17 31-M.--17 28-09-2016 28--05>-20 l 6 17-No'r'-17
2016 2000 2100005596 31-03-2017 17-04 -2017 30-06-2016 KR INR OCOA 143659 Sk,-oa 120001170
KONICA MINOLTA BUSI 6 15% 5 I 182203503 17-Nov-17 31-Mar-17 28-®-2016 28-09-2016 17-Nov-17
2016 2000 2100005597 3 1-03-2017 17-0<-2017 3 1-05-2016 KR INR OCOA 143652 Sl.")'00 120001170
KONICA MINOLTABUSl 73 1m 70 3 1822027"2 o:>-Ool-17 31-Mor-l7 29-08-2016 29-08-2016 05--0ct-17
2016 2000 2100005598 3 1-03-2017 17-04-2017 16--02-2017 KR INR OCOA 143652 IREO PVT L" FELIX ADVISORY PVT I
130000259 6,<.i9 lS% S.879 21 0 182200252 17-Apr-17 31-Mar-l7 17-0l-2017
2016 2000 2 I00005598 3 1-03-2017 17-04-2017 16--02-2017 KR JNR OCOA 143659 IREO PVT L" FELIX ADVISORY PVT I
130000259 217 llli 210 7 182200252 17-Apr-17 31-Mw-17 17.05-2017
2016 2000 2100005618 31-03-2017 1&-04-2017 30-03-2017 KR INR OCOA 1-43659 IREO PVT L. 100000025
RICOH INDIA LTD. 469 1m 453 16 182201615 07-Jul-17 3 J-Mar-17 28-06-2017 28--06-2017 07-Jul-17
2016 2000 2100005618 31.03-2017 18-04-2017 30-03-20 17 KR INR OCOA 143652 IREO PVT L" 100000025
RICOH INDIA LTD 13, )29 llli 12.6 77 452 182:20161:5 07.J11.I1 31-Mar-17 28-06-2017 28-06-2017 07-Jul-17
2016 2000 2100005621 31-03-2017 IS-04-2017 3().())-2017 KR INR OCOA 143659 IREO PVT L" 100000025
RICOH INDIA LTD. 26 llli 25 I 182201615 07-JuH 7 3 1-Mar-17 28-06--2017 28.()6..2017 QJ.Jul-17
2016 2000 2 10000562 1 31-03-201 7 18-04-2017 30-03-2017 KR 1NR OCOA 1'3652 IREO PVT L" 100000025
RICOH INDIA LTD. 733 llli 708 25 18220161 S 07-Jvl-17 3I-Mar-17 28-06-2017 28--()6..2017 07-Jul-1 7
2016 2000 2100005622 31-03-2017 18-04-2017 30-03-2017 KR INR OCOA 143652 M......,l Sen 100000025
RICOH !NOIA LTD. 394 llli 381 13 182201615 07-1,1-17 3I-M ar-17 28-06-2017 28-06-2017 07-Jul-I7
2016 2000 2100005622 3 1-03-2017 18-0<-2017 30-03-2017 KR INR OCOA 143659 M..,..I Sen 100000025
RICOH !NOIA LTD. 14 15% I◄ 0 182201 615 07-fol-17 3 1-Mor-17 28-06-2017 28--0<>-2017 07-JuJ.L?
20 16 2000 2100005625 31-03-2017 18-04-2017 3 1-03-2017 KR INR OCOA 143652 IREO PVT L" 120001170
KONICAMJNOLTABUSI 153 llli 148 5 182202102 05-0ol-17 3 1-Mar-17 29-06-2017 29--06-20 17 OS.Qct-17
2016 2000 2100005625 31 -03-2017 18-0<-2017 3 1-03-2017 KR INR OCOA 143659 IREO PVT L. 120001 170
KONICA MINOLTA BUSI l 15% 5 0 182202102 Ol-Oct-17 31-Mar-17 29-06-2017 29-~2017 05-0:l-17
201, 2000 2100005626 3 1-03-2017 17-0<-2017 31-03-2017 KR INR OCOA l-436W IREO Pvr L" FELIX ADVISORY PVT. I
130000259 500 llli 483 17 182200252 l 7-Apr-17 31-Mar-17 29-06-2017
2016 2000 2 I00005626 31-03-2017 17-04-2017 3 1-03-2017 KR INR OCOA 143652 IREO PVT L" FELIX ADVISORY PVT. I
130000259 14.000 15% 13.$ 17 483 182200252 17-Apr-17 3I-Mt,-17 29-06-2017
2016 2000 2 100005645 3 1-03-201 7 19-0<-2017 28-02-2017 KR INR OCOA 143653 IREO PVT L" SRI DURGA SECURllY I
120000516 37.153 llli 35.872 1,281 182200958 02-Jwa-17 3 1-Mar-17 29.05-2017 29-0S-2017 02-Jwt-17
20 16 2000 2100005645 31 -03-2017 19-0<-2017 28-02-2017 KR INR OCOA 143658 IREO PVT L" SRI DURGASECURllY I
120000516 1.327 15% 1.281 46 182200958 02-Jun-17 31-Mar-17 29-05-20 17 29--0S-2017 02-Ju.a-17
2016 2000 2 100005698 3 1-03-201 7 20-04-2017 27-03-2017 KR INR OCOA 143652 IREO PVT L" 100000227
KYOCERA DOCUMENT . 730 15% 705 25 182201057 06-Jun-l7 31-Mar-17 25-06-2017
2016 2000 2 I00005698 3 1-03-2017 20-04-2017 27-03-2017 KR INR OCOA 143659 IREO PVT L" I 00000227
KYOCERA DOCUMENT 26 15% 2l I 182201057 06-Jun•l7 31-Mar-17 25-06-2017
2016 2000 210000574 2 3 1-03-2017 20-04-2017 16-03-2017 KR INR OCOA 143653 IREO Upc°", 120000m
COLLECTIONS 2.709 llli 2.615 94 182200924 02-Jun-17 3 1-Mar-17 14---06-2017
2016 2000 210000S7"2 3 1-03-2017 20-0<-2017 16-03-2017 KR INR OCOA 143658 IREO Upc.,., 1200002n
COLLECTIONS 97 1m 93 4 182200924 02-Jun-17 3 1-Mar-17 14--06-2017
2016 2000 2100005746 31-03-2017 20-04-2017 16-03-2017 KR INR OCOA 143653 IREO PVT L" 1200002n
COLLECTIONS 2.616 IS% 2,526 90 182200924 02-Jun-l 7 31-Mar-17 14--06-2017
2016 2000 2100005746 3 1-03-2017 20-04-2017 16-03-2017 KR INR OCOA 143658 IREO PVT L" 120000272
COLLECTIONS 93 15% 90 3 182200924 02-Jun-l 7 3 1-M•-1 7 14--06-2017
2016 2000 21000057<7 3 1-03-2017 20-04-2017 16-03-2017 KR INR OCOA 143658 M,naecd Sen 1200002n
COLLECTIONS 290 I~ 280 10 182200924 02-Jun-l 7 31-M•-17 14-06•20l7
2016 2000 21 000057<7 31-03-2017 20-0<-2017 16-03-2017 KR INR OCOA 143653 M..,..S Sen 120000272
COLLECTIONS 8.126 15% 7,846 280 182200924 02-Jun-l7 J l •M•-17 1-4-06--2017
2016 2000 21000057'8 31-03-2017 20-04-2017 16-03-2017 KR INR OCOA 143658 IREO PVT L" 1200002n
COLLECTIONS 29 IS% 28 I 182200924 02-Jun- 17 31-Mar-17 14-06-2017
2016 2000 2100005748 3 1-03-2017 20-04-2017 16-03-2017 KR INR OCOA 1'3653 IREO Pvr L" 1200002n
COLLECTIONS 801 15% m 28 182200924 02-Jun-17 3 1-M•-17 1..--06-2017
2016 2000 2100005751 3 1-03-2017 20-0<-2017 16-03-2017 KR INR OCOA 143653 M,na&<d Sen 120000272
COLLECTIONS 566 15% 546 20 182200924 02-Ju.n-17 3 1-Mar-17 14-06-2017
2016 2000 2100005751 3 1-03-2017 20-04-2017 16-03-2017 KR INR OCOA 143658 M..,&<d Sen 1200002n
COLLECTIONS 20 15% 20 0 182200924 02-Jwt-17 31-M•-17 14--0<>-2017
2016 2000 2100005753 31-03-2017 20-04-2017 3 1-03-2017 KR INR OCOA 143653 lREO PVT L" 120001298
RD HORTICULTURE& I 34.819 15% 33.618 1.201 l8220'.l749 06-0;-17 31-Mar-17 29-06-2017 29--06-20 17 06-0ot-17
2016 2000 2100005753 31-03-2017 20-0<-2017 3HlJ-2017 KR 1NR OCOA 143658 IREO Pvr L" R DHORTICULTURE&l
12000129ll 1.244 1m 1,201 43 182201749 06-0a-17 31-Mar-17 29--06-2017 29.o6-20 17 06-0ot-17
2016 2000 2100005754 31-03-2017 21-04-2017 31-03-2017 KR INR OCOA 143653 IREO PVT L" 120000272
COLLECTIONS 23.833 IN 23.011 822 182200924 02-Jun-17 31-Mar-17 29-06-2017
2016 2000 2100005754 3 1-03-2017 21-04-2017 31-03-2017 KR INR OCOA 143658 1R£0 PVT L" 1200002n
COLLECTIONS 851 JS% 822 29 182200924 02-Jun-17 3I-Ma,-17 29-06-2017
2016 2000 2100005755 31-03-2017 21-04-2017 31-03-2017 KR INR OCOA 143658 IREO PVT L" 120001101
CHANDRA HORTI SERV 871 15% 841 30 182202596 04-0cl- 17 31-Mar--17 29--06-20 17 29-06-2017 04-◊<t-17
2016 2000 2100005755 3 1-03-2017 2 1-0<-2017 31-03-2017 KR INR OCOA 143653 IR£0 PVT L" 120001101
CHANDRA HORTI SERV 24,379 1m 23.539 840 I82202 596 04-0cl-17 31-Mar-17 29-06-2017 29--06-2017 04-0«-17
2016 2000 2100005756 3 1-03-2017 21 -0<-2017 3 1-03-2017 KR INR OCOA 143653 IREO PVT L" G REEN LANDSCAPE SO
120001156 24.018 1m 23. 190 828 182203046 23-0:l-17 31-Mar-17 29-06-2017 29-06--2017 23-0cl-17
2016 2000 21 00005756 3 1-03-2017 2 1-04-2017 31-03-2017 KR INR OCOA 143658 lREO PVT L" GREEN LANDSCAPE SO
120001156 858 15% 821 30 182203046 23-0:l-17 3 1-Mar-17 29-06-2017 29--06-2017 23-0cl-11
2016 2000 2100005757 3 1-03-20 17 21-0<-20 17 31-03-2017 KR INR OCOA 143659 IREO PVT L" 100002552 IMMORTAL CORPORAT 499 15% 481 18 182202831 IO-OCl- 17 31 -Mar-17 29-06-2017 29-06-2017 IO-Oct-17
2016 2000 2100005757 3 1-03-2017 2 1-04-2017 3 1-03-2017 KR 1NR OCOA 143652 IREO PVT L" 100002552 IMMORTAL CORPORAT 13.958 1m 13.477 48 1 182202831 111-0:1-17 31-Mar-17 29-06-2017 29.()6..2017 lO-Oct-17
2016 2000 2 I00005758 3 1-03-201 7 21-0<-20 17 3 1-03-2017 KR INR OCOA 143658 IREO PVT L" 120000516 SRI DURGA SECURITY I 1.413 1m 1,364 49 182200958 02-Juo-1 7 31-Mar-17 29-06-2017
2016 2000 2100005758 31-03-2017 21-0<-20 17 3 1-03-2017 KR 1NR OCOA 143653 IREO PVT L" 120000516 SRI DURGA SECURITY A 39.556 I~ 38.192 1.364 182200958 02-Jun-17 31-Mar-17 29-06-2017
2016 2000 2100005766 3 1-03-2017 21-0<-2017 16-03-2017 KR 1NR OCOA 143653 Ciurp)II Hill! 120000272 COLLECTIONS 301 llli 291 10 182200924 02-Jll'l-17 31-M.v-17 14-06-2017
2016 2000 2100005766 3 1-03-2017 21-0<-2017 16-03-2017 KR INR OCOA 1436S8 Gurpon H1l11 120000272 COLLECTIONS II 1m 10 I 182200924 02-J,m-l 7 3 1-Mar-17 14-06-2017
2016 2000 2100005767 3 1-03-2017 21-0<-2017 16-03-2017 KR INR OCOA 143653 Gw-poo Hill! 120000272 COLLECTIONS l.320 1m 5.137 183 182200924 02-Jwt-17 3 1-Mar-17 14-06--2017
2016 2000 2100005767 3 1-03-2017 21-04-2017 16-03-2017 KR JNR OCOA 143658 Gw-poo Hilb 120000272 COLLECTIONS 190 1m 183 7 182200924 02-Jlrl•l7 3 l•Mar•l7 14-06-2017
2016 2000 2100005768 31-03-2017 21-0<-2017 3 1-03-2017 KR 1NR OCOA 143659 Manac<d Sen 120001012 V INSPIRER FAOUTY P, 887 llli 856 31 1B220♦on O:l-Jan-18 31-Mor-17 29-06-2017 29-06-2017 03-Jan-I8
2016 2000 2100005768 3 1-03-2017 21-0<-2017 3 1-03-2017 KR INR OCOA 143652 Manaacd Sen 120001012 V INSPIRER FACILITY P, 24.827 llli 23.971 856 182204077 0:l-Jtn-18 31•Mar-1 7 29--06-2017 29-06-2017 03-Jaa-I8
2016 2000 2100005769 31.03-2017 21 -04-2017 31-03-2017 KR JNR OCOA 143652 M""IOCI Sen 120001012 V INSPIRER FACILITY P, 357 Im 345 12 182204on 0J..hn-I8 31-M••l7 29..(16..2017 29-06-20 17 03-Jan-l S
2016 2000 2100005769 31-03-2017 21-0<-2017 31-03-2017 KR INR OCOA 143659 ManljlCd Sen 120001012 V INSPIRER FACILITY P, 13 I~ 12 I 1822040n 03-Jm.l8 31-Mar-17 29-06--2017 29--06-2017 03-Jan-18
2016 2000 2100005no 31-03-2017 21-0<-2017 31-03-2017 KR INR OCOA 10653 IREO PVT L" 120000250 SUNNY SEOJRITY SER\ 3.980 1m 3.843 137 182201060 06-Ju,,.(7 31-Mar-1 7 29-06-2017
2016 2000 2100005no 31-03-2017 21-0<-2017 31-03-2017 KR INR OCOA 143658 IREO PVT L" 120000250 SUNNY SECURJlY SER\ 142 1m 137 S 182201060 ()6.Jim--17 3 1-Mar-17 29-06.2017
2016 2000 210000,m 31-03-2017 21-0<-2017 31-03-201 7 KR INR OCOA 143658 IREO Pvr L" 120000250 SUNNY SECURITY SER\ 914 U% 883 31 182201060 06-Jun-17 31-Mar-17 29--0<>-2017
2016 2000 2100005n2 31-03-2017 21 -0<-2017 31-03-201 7 KR INR OCOA 143653 IREO PVT L" 120000250 SUNNY SECURITY SER\ 25_.594 llli 24.712 882 182201060 06-.Ju-l7 3I-Mar-17 29-06-2017
2016 2000 21 00005n1 31-03-2017 21-0<-2017 31-03-201 7 KR INR OCOA 143653 IREO PVT L" 140000052 VARSHA SEC URITY sY! 7,928 U% 7.654 274 182202456 l5-Sq,-17 31-Mar- l 7 29-06-2017 29-06-2017 l5-Sq,-17
2016 2000 2100005n1 31 -03-2017 21-0<-2017 31-03-2017 KR INR OCOA 143658 IREO PVT L" 140000052 VARSHA SECURllY SY! 283 U% in 10 182202456 l5-Sq,-17 31-M•• l7 29-06-2017 1:C)-06-2017 15-Scp•l7
2016 2000 21oooosn8 31-03-2017 21-04-2017 31-03·2017 KR INR OCOA 143653 IREO PVT L" 140000052 VARSHA SECURllY SY! 22J8S IS% 21.517 768 182202456 l5-Sq)-17 ll•M•-1 7 29-06-2017 29-06-2017 IS-Sq,-17
2016 2000 2100005m 31-03-2017 21-04-2017 31-03-2017 KR INR OCOA 143658 IREO PVT L" 140000052 VARSHA SECURllY SY! 796 IS% 768 28 182202456 l5-Sq,-17 3 I -Mor- 17 29-06-2017 29-06-2017 l 5-Sq,-17
2016 2000 21 00005780 31-03-2017 21-04-2017 31-03-2017 KR INR OCOA 143659 IREO PVT L" 120000535 COLLIERS INTERNATIO 1.944 IS% 1.877 67 182202435 14-Sq,-17 3 1-Mar- l 7 29-06-2017 29-06-2017 14-Sq,-17
2016 2000 2100005780 31-03-2017 21-04-2017 3 1-03-2017 KR INR OCOA 143652 IREO PVT L" 120000535 COLUERS INTERNATIO S4.4 19 15% 52,S42 1.877 182202435 14-Sq,-17 3I-M•-1 7 29--0<>-2017 29-06-2017 14-Sq,-17
2016 2000 2100005781 31 -03-2017 21-04-2017 31-03-2017 KR INR OCOA 143652 IREO PVT L" 120000535 COLLIERS INTERNATIO 23,174 15% 22.375 799 182202435 14-Sq)-17 31-Mar-17 29-06-2017 29-06-2017 14-Scp-l 7
2016 2000 2100005781 31-03-2017 21-0<-2017 3 1-03-2017 KR INR OCOA 143659 IREO PVT L" 120000535 COLLIERS INTER.>IATIO 128 IS% 799 29 11220205 l4-Sq,-17 31-Mor-1 7 29--0<>-2017 29-06-2017 14-Scp-17
2016 2000 2100005782 3 1-03-2017 21-04-2017 3 1-03-2017 KR INR OCOA 143659 IREO PVT L. 120000535 COILIERS INTERNATIO 40 IS% 31 2 18220205 14-Sq,-1 7 3I-M or-17 29--0<>-2017 29--0<>-2017 14-Sq,-l 7
2016 2000 2100005782 3 1-03-2017 21-0<-2017 3 1-03-2017 KR INR OCOA 143652 IREO PVT L" 120000535 COLUERS INTERNATIO 1.107 1$% 1.068 39 11220205 l4-Scp-1 7 31-M••l7 29~2017 29--06-2017 14-Scp-l 7
2016 2000 2100005786 31-03-2017 21-0<-2017 3 1-03-2017 KR INR OCOA 143659 Gurpan Hilb 120000903 NECESSA SECURITY & I 17 IS% 16 I 182202186 16-Aq-17 31-M•-17 29--06-2017 29..()6.2017 l6-Ana-17
2016 2000 2100005786 31-03-2017 21-0<-2017 3 1-03-2017 KR INR OCOA t06S2 Gurpon Hill! 120000903 NECESSA SECURITY & I 476 1m 460 16 112202186 16-Au1•17 31-Mw-17 29-06-2017 29--0<>-2017 l6-Auc-17
2016 2000 2100005793 3 1-03-2017 21-0<-2017 3 1-03-2017 KR INR OCOA l436S9 IR.£O Up«M, 130000359 S.GHOSH ARCHITECTS I -4,656 IS% 161 1&0100208 21-Ap<-17 31-M•l7
,.
4.495 29-06-2017
201 6 2000 2100005793 31-03-2017 21-0<-2017 3 1-03-2017 KR INR OCOA 10652 IREO UptCMl 130000359 S.GHOSH ARCHITECTS I 1.30,359 IS¾ 1.25.863 4 .496 110100208 21-Ap<-17 31-Mw-17 29-06-2017
201 6 2000 2 I 00005805 31-03-2017 24-04-2017 16-03-2017 KR INR OCOA l436l8Sk,oo 120000272 COILECTIONS 193 187 6 112200924 02-Jun-17 3 I-Mar-17 l4--0<>-2017
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2016 2000 2 100005805 3 1-03-2017 24-0<-2017 16-03-2017 KR 1NR OCOA 1436'3 51..) '0R 120000272 COLLECTIONS 5,41 7 I~ 5.230 187 112200924 02-Jwt-17 31-Mar-17 14-06-2017
2016 2000 2100005809 3 1-03-2017 24-04-2017 3 1-03-2017 KR INR OCOA 143658 IREO PVT L" 120000272 COLLECTIONS 9 llli 9 0 182200924 02-Jut-17 l l •Mar--17 29-06-2017
2016 2000 2 I 00005809 3 1-03-2017 24-0<-2017 3 1-03-2017 KR 1NR OCOA 143653 IREO PVT L" 1200002n COLLECTIONS 261 llli 252 9 182200924 02-Jun-17 31-Mar-1 7 29-06-2017
2016 2000 2 100005813 31-03-2017 24-04-2017 3 1-03-2017 KR INR OCOA 143653 Sk)'011 120000272 COILECTIONS 414 IS% 400 14 182200924 02-Ju.o:-n 31-Mar-17 29-06-2017
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2016 2000 2100005814 31-03-2017 24-0<-2017 3 1-03-2017 KR 1NR OCOA 143653 M......,d Sen 120000272 COLLECTIONS 690 IS% 666 24 112200924 02-Jun-17 31-Mar-17 29-06-2017
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401
MAHINDRA AND MAHINDRA LIMITED

Standalone Financial Statements for period 0 1/04/2018 to 31/03/2019
[700300] Disclosure of general information about company

Un l ess oth erw1se spec1'Ii1ed aII monetary va ues are .m L a khso f lNR
01/04/2018 01/04/2017
to to
31/03/2019 31/03/2018
Corporate identity number U70102MH20 10PTC203618
Pennanent account number of entity AAACW9691A
5th Floor, Mahindra
Towers, Worli, Mumbai
Address of registered office of company
400018, Maharashtra,
India ........_
Commercial and
Type of industry
Industrial
Registration date 02/06/20 10 --....
Company limited by
Category/sub-category of company shares/ I ndian
Non-Government Company
Whether company is listed company No
Date of board mcctinJ? when final accounts were approved 17/04/2019
'"""
Period covered by financial statements 12 Months 12 Months
Date of start of reportinJ? period 01/04/2018 01/04/20 17
Date of end of reporting period 31/03/2019 31/03/2018
Narurc of report standalone consolidated Standalone
Content of report Financial Statements
Description of presentation currency INR
Level of roundinJ? used in financial statements Lakhs
Type of cash flow statement Indirect Method
Whether company is maintaining books of account and other relevant
Yes
books and papers in electronic form
Mahindra & Mahindra Ltd.
Complete postal address of place of maintenance ofcomputer MITC Building, Akurli
Road, Ppp. to Yellow Gate,
servers (storing accounting data)
Samata Nagar, ......
Kandivali-East
Name of city of place of maintenance of computer servers (storing
Mumbai
accounting data)
Name of state/ union territory of place of maintenance of
Maharashtra
computer servers (storing accounting data)
Pin code of place of maintenance of computer servers (storing
4000 18
accounting data)
Name of district of place of maintenance of computer servers
Mumbai
(storing accounting data)
ISO country code of place of maintenance of computer servers
91
(storing accounting data)
Name of country o f place of maintenance of computer servers
India
(storinJ? accountinR data)
Phone (with STD/ ISD code) of place of maintenance of computer 022-28025395,
servers (storing accounting data) 022-28025396
Name of the service provider Mahindra & Mahindra Ltd.
Internet protocol address of service provider Nor Applicable
Location of the service provider Mumbai
Whether books of account and other books and papers arc maintained
No
on cloud
"
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MAHiNO RA AND MAHINOI IA IMITED Standalone Financial Statements for periocl 01/0412018 to 31/0312019
-
402
Unless otherwise soccified, all monetary C . r e in Lakhs o f ~ ~ )
01/0~" 01 '"' "' ~ .......
to to
3 1/03/2019 3 1/03/2018
Statement of profit and loss [Abstract]
Income (Abstract]
~
---
Revenue from operations 39,014.36 24,408.41
Other income 349.27 395.05
Total income 39,363.63 24,803.46
Expenses [Abstract]
Cost of materials consumed 0 0
Changes in inventories of finished goods, work-in-progress and
-36,163.41 -4,096.74
stock-in-trade
Employee benefit expense 0 0
Finance costs 2,235.89 578.46
Depreciation, depletion and amortisation expense 166.03 207.44
Other expenses
(A) 69,235.96 (B) 25,320.84
Total expenses 35,474.47 22,010 --..
Profit before exceptional items and tax 3,889.16 2,793.46
Total profit before tax 3,889.16 2,793.46
Tax expense [Abstract]
Current tax 0 1,070
Deferred tax 1,169.87 -16.18
Total tax expense 1,169.87 1,053.82
Total profit (loss) for period from continuing operations 2,719.29 1,739.64
Total profit (loss) for period 2,7 19.29 1,739.64
Comprehensive income OCI components presented net of tax (Abstract]
Whether company has other comprehensive income OCI components
No No
presented net of tax
Other comprehensive income net of tax [Abstract]
Other comprehensive income that will be reclassified to profit
0 0
or loss, net of tax, others
Total other comprehensive income that will be reclassified to
0 0
profit or loss, net of tax
Total other comprehensive income 0 0
Total comprehensive income 2,719.29 1,739.64
Comprehensive income OCI components presented before tax [Abstract]
Whether company has comprehensive income OCI components presented
No No
before tax
Other comprehensive income before tax [Abstract]
Income tax relating to components of other comprehensive
income that will not be reclassified to profit or loss
[Abstract]
Aggregated income tax relating to components of other
comprehensive income that will not be reclassified to 0 0
profit or loss
Total other comprehensive income 0 0 --..
Total comprehensive income 2,719.29 1,739.64
Earnings per share explanatory [TextBlock]
Earnings per share [Abstract]
Basic eamin~s per share (Abstract]
-..
Diluted earnings per share (Abstract]
.......
.......
55
,...__
&
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403
........_
......
FORM BR-VII
(See Code 4.10(2), (4) and (5))
Form of Occupation Certifica
oc
From
Director,
Town & Country Planning Department,
Haryana, SC0-71-75, Sector-17-C, Chandigar
Tele-Fax: 0172-2548475; Tel. : 0172-2549851,
E-mail: tcpharyana7@gmail.com
Website www.tcpharyana.gov.in
To
.......
Base Export Pvt. Ltd. and others,
nd
5-1 , 2 Floor, Back Portion, Shahpur,
New Delhi· 11049.
Memo No. ZP-435/ AD(RA)/2019/ _ _ /_t/_~_./___Dated: · J.-2. - t:J ( - /1

Whereas Base Export Pvt. Ltd. and others has applied for the issue of an
occupation certificate on 29.06.2018 in respect of the buildings described below:·
DESCRIPTION OF BUILDING
City: Gurugram: •
• Licence No. 16 of 2008 dated 31.01.2008.
• Total area of the Group Housing Colony measuring 17.55 acres.
• Sector-59, Gurugram.
• Indicating description of building, covered area, towers, nature of building etc. .......
Tower/ No of No. of No. of Floors FAR Sanctioned FAR Achieved
Block dwelling Dwellin Area in % Area in %
No. units g Units Sqm. Sqm.
sanctione
d .......
Tower-I 120 120 Ground Floor 24729.933 38.908 24703.075 38.866
to 31 " Floor ,.__
EWS 65 65 Ground Floor 1700.08 2.675 1685.39 2.652
th
to 4 Floor
NON-FAR AREA IN SQM.
Upper and Lower 10845.627 10957.412
Level Basement
Guard Room ft 74.587 74.587
Meter Room
Mumtv' 12.34 12.34
I hereby grant permission for the occupation of the said buildings, after considering
NOC from fire safety issued by Director General, Fire Service, Haryana, Panchkula,
Environment Clearance issued by State Environment Impact Assessment Authority, Haryana,
Structure Stability Certificate given by Dr. Vinod Jain, M.Tech. (Structure), Public Health
Functional reports received from Superintending Engineer (HQ), HSVP, Panchkula f:t Chief
Engineer-I , HSVP, Panchkula & Certificate of Registration of lift issued by Inspector of Lifts•
cum-Executive Engineer, Electrical Inspectorate, Haryana and after charging the composition
charges amount of ~ 12,53,085 /- for the variations vis-a-vis approved building plans with
following conditions: •
1. The building shall be used for the purposes for which the occupation certificate is
being granted and in accordance with the uses defined in the approved Zoning
.......
Regulations/ Zoning Pl an and terms and conditions of the licence.
2. That you shall abide by the provisions of Haryana Apartment Ownership Act, 1983 and
Rules framed thereunder. All the flats for which occupation certificate is being
granted shall have to be compulsorily registered and a deed of declaration will have
to be filed by you within the time schedule as prescribed under the Haryana ........_
Apartment Ownership Act 1983. Failure to do so shall invite legal proceedings under
the statute.
3. That you shall apply for the connection for disposal of sewerage, drainage & water
supply from HSVP as and when the services are made available, within 15 days from
its availability. You shall also maintain the internal services to the satisfaction of the
Director till the colony is handed over after granting fina_l completion.
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404
4. That you shall be fully responsible for supply of water, disposal of sewerage and
storm water of your colony till these services are made available by HSVP/State
Government as per their scheme.
5. That in case some additional structures are required to be constructed as decided by ,....
HUDA at later stage, the same will be binding upon you.
6. That you shall maintain roof top rain water harvesting system properly and keep it
operational all the time as per the provisions of Haryana Building Code, 2017.
7. The basements and stilt shall be used as per provisions of approved zoning plan and
..I 8.,
building plans .
That the outer facade of the buildings shall not be used for the purposes of
advertisement and placement of hoardings.
9. That you shall neither erect nor allow the erection of any Communication and
Transmission Tower on top of the building blocks.
10. That you shall comply with all the stipulations mentioned in the Environment
clea1 ance issued by State Environment Impact Assessment Authority, Haryana Vide
No. SEIAA/HR / 2014/1 046 dated 06.08.2014.
11. That you shall comply with all conditions laid down in the Memo. No. FS/2018/ 84
dated 09.08.2018 of the Director General, Fire Service, Haryana, Panchkula with
regard to fire safety measures.
12. You shall comply with all the conditions laid down in Form·D issued by Inspector of
Lifts·cum-Executive Engineer, Electrical Inspectorate, Haryana, HSVP Primary School
Building, Block•C·Z, Sushant Lok•I, Gurugram.
13. The day & night marking shall be maintained and operated as per provision of
International Civil Aviation Organization (ICAO) standard.
14. Thal you shall use Light-Emitting Diode lamps (LED) In the building as well as street
lighting.
15. That you shall impose a condition in the allotment/possession letter that the allottee
shall used Light-Emitting Diode lamps (LED) for internal lighting, so as to conserve
ene,gy.
16. That you shall apply for connection of Electricity within 15 days from the date of
issuance of occupatio11 cert i ficate and shall submit the proof of submission thereof to --..
this office. In case the electricity is supplied through Generators then the tariff
charges should not exceed the tariff being charged by DHBVN.
17. That provision of parking shall be made within the area earmarked/designated for
parking in the colony and no vehicle shall be allowed to park outside the premises.
18. That an area measuring 0K-16M (708.19875 sqm FAR) (Kh. No. 19// 19/1/1 of Village
Behrampur has freezed due to pending investigation in Cw1l Appeal No. 8977 of 2014
& 9211-13 of 2016.
19. Any violation of the above said conditions shall rende~hr occupation certificate null
and void. I~
(K. Makrand Pandurang, IAS)

Direct9r, Town and Country Planning,
/'-f!aryana, Chandigarh.
Endsl. No. ZP-435/AD(RAl/2019 I c1 :::,:;.. Dated: - 22-1--/ /
A copy Is forwarded to the following for information and necessary action: ·
1. Tne t>irector General, Fire Service, Haryana, Panchkula with reference to his office
i Memo. No. FS/ 2018/84 dated 09.08.2018vide which no objection certificate for
1
occupation of the above-referred buildings have been granted. It is requested to ensure
compliance of the conditions imposed by your letter under reference. Further in case of
any lapse by the owner, necessary action as per rules should be ensured. In addition to
the above, you are requested to ensure that adequate fire fighting infrastructure is
created at Gurugram for the high-rise buildings and concerned Fire Officer will be
personally responsible for any lapse/ violation.
Z. Chief Engineer·!, HSVP, Panchkula with reference to his office memo no. 161611 dated
09.08.2018.
3. Superintending Engineer (HQ) , HSVP, Panchkula with reference to his office memo no.
161580 dated 09.08.2018. -,
4. Senior Town Planner, Gurugram with reference to his office memo. No. 6601 dated
20.08.2018.
5. District Town Planner, Gurugram with reference to his office memo. No. 8542 dated
16.08.2018.
~ ' Nodal Officer, website updation.
(Sanjay K m
District Town Planner ,
For Director. Towyii Country Planning,
L, yana, Chandigarh.
,-
.....
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405
BASE EXPORTS PRIVATE LIMITE.D
lrco Campus. Ardwicw Orivc. lrco City. Golf Course Lxtcnsion Road. Uurgnon - 122 101 .
l-laryana I;-mai 1-cPord ination.d1cl(/i)irco. in
Ref No: Base/BIP/2018/61 - -- -.-, - -.

/ -~..... ;.-~!! c,
~ ,': ·... - j
'"'
To f?( ;1J. 1y ~1<, .• "'
O \ r , ... t '
The Director General ~ JJ ~- -
.....,
Town and Country Planni • ul
Chandigarh .......
Sub:- Permission for Joint development rights and marketing rights for an area measuring
6. 79375 acres with Mahindra Homes Pvt. Ltd. and IREO Pvt Ltd out of total licensed area
measuring 17.55 acres w .r.t. license no 16 of 2008 dated 31.01.2008 granted to develop
Group Housing Colony in the revenue estate of vill age Behrampur,Sector ~9, Gurugram
,-t,.p-154 ·
Ref:- Your in principle approval letter memo no LC-1042-JE(VA}2018/2414 dated 16.01.2018 ........
Dear Sir ~~"°'\~ .......
We have requested Joint development rights ;ind marketing riehts for an nrea measuring 6.793;5 [ t.t\\_\
acres with Mahindra Homes Pvt. Ltd. and IREO Pvt Ltd under the policy no PF-SlA/2015/2/08
dated 18.02.2015, and on our request your good office has granted in principle approval vide D/P(\(Si
letter under r eference. So we submitting the compliance of in principle approval as mentionedl /
below for final approval:- l't\
1. In compliance of clause no 1 are we are submitting the copy of collaboration agreements ----
\4½
already executed between the parties.
--.f,£ tv)
2. In compliance of cl ause no 2, 3 & 5 w e Mc submittine an undertaking executed by Base
Exports Pvt Ltd.
3. In compliance of clause no 4 we are submitting j oint undertnking executed by Mahindra

Homes Pvt Ltd & IREO Pvt Ltd.
......
4. In compliance of clause no 6 we have informed the all the allottees about the proposed
joint development, given a dvenbernent in Indian Cxpress, f'.inancial tx p rc.~s :ind fan ,:)t;i
on 16.02.2018 and uploaded the copy of in principle approval on our website.
5. In compliance of clause no 3 we have paid the billancc administrntive charges or Rs.

41,93,700/ thro11gh e-payment link available 011 department website. The copy of E
Regd. Office: 304, Kanchan House, Karam Pur;i Commr•ric:il Complex, New Oelhi-110015
E111.1il:h.1s,•.,•;,p0<·r!~,i,·,~111.1il.n1111.l IN 1, 1:, 1•v•; 11 ~'~"'I' l l 1,111 11,· ( I 'll llt ~ l -1795tlll0) ....
&
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406
Payment Tran sact ion No TCP3113183295978 and GR No. 34379759 is attached herewith
for your information and record.
It is therefore requested to kindly approve Joint development ri ghts and marketing rights for an
area measuring 6.79375 acres with Mahindra Homes Pvt. Ltd. and IREO Pvt Ltd out of total .....
licensed area measuring 17.55 acres w. r.t. license no 16 of 2008 dated 31.01.2008 grant ed to
develop Group Housing Colony in th e revenue estate of village Behrampur, Sector 59, Guru gr am
Thanking You,
Yours Sincerely,
For Base Exports Pvt. Ltd.
~J, tJf3-l-:c
(Mohammad Asim)
........
Authorised Signatory
Encls.:-
1. Copy of Collaboration Agreements
2. COY~R1~;.j ~r-,lff..R ·
3. Undertaking Base Exports Pvt Ltd .......
4. Undertaking Mahindra Homes Pvt Ltd & IREO Pvt Ltd
5. Copy of E-Payment Receipt
6. Co py of Notice sent to Allottees
7. Copy of Advertisement given in news papers
8. Copy of Screenshot of our website.
........
.....
-
Regd . Office: 304, Kanchan House, Karam Pura Commerirnl Complex, New Delhi-110015
J:111uil: base.c~p,,.. r1sru15rn,,il,·,,,n: U N # U'i l'XJ91ll .21l<l!il'IC l40'.\l,.I (Ph· ll l::!-1--17')5000)
,...,_
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407
Office of Senior Town Plannel', Gurugram
DEPARTMENT OF TOWN & COUNTRY PLANNING, HARV ANA
SECTOR- I 4, HUDA COMPLEX, 3RD FLOOR, GURUGRAM
TEL + FAX: (,124-2305872
.gurugram.tcp@gmail.com
To - _/ .)
11-;·; ;0lf'·~"
.......
Town & Country Planning, Haryana,
SCO No. 71-75, Sector~ I 7C, Chandigarh.
))r'7 (5K)
Subjcr.t: Permission for Joint 1evelopment rights and marketing rights for an area
measuring 6.79375 acres with Mahindra Homes Pvt. Ltd. and IREO Pvt. Ltd. out
of total Licensed area mc::asuring l 7.55 acres w.r.t. License no. 16 of 2008 dated
31.01.2008 granted to develop Group Housing Colony in the revenue estate of
village Behrampur, Scctor-59, Gurugrnm.
Rcfercn,.;e:
The Permission for Joint development rights and marketing rights for an area measuring
6.79375 acres with Mahindra Homes Pvt. Ltd. and IREO Pvt. Ltd. out of total Licensed area measuring
i 7 .55 acres w.r.t. License no. 16 of 2008 dated 31.01.2008 granted to develop Group Housing Colony
in the revenue estate of village Behrampur, Sector-59, Gurugram were approved in-principle vide memo
under reforer,ce with a condition that objections will be invited from the existing allottees regarding
amendment in Joint development rights through an advertisement to be issued three newspapers (Two
......
English & Oue Hindi).
Accordingly, the colonizer had given a public notice in The Jndian Express (English),
The Financial Express (English) and Jansalta (Hindi) on 16.02.2018 inviting objections from the
existing allottees. The colo~izer has also hosted the information about the Permission for Joint
development rights on the web site for information to aH such existing allottees. A photocopy of the
same is enclosed herewith for reference. It is relevant to mentior. that the colonizer has submitted an
undertaking to effect that they have not received any objection f~om the existing nllottees on proposed "'"'
Permission for Joint development rights. The Circle Office has alw not received any objection
rt:gan.iing subjc:,:r cited macter.
The report is submineci for kind perusal and taking funlter necessar.r action pieas·~.
.......
DAIAs above.
........
Sen ~ .......
Gurugram Circle, Gurugram
,.....,_
......
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.
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(
408

SC0-71-75, 2nd Floor, Sector 17 C, Chandigarh
Phone: 0172·2549349, e-mail:tcpharyana7@gmail.com
website:·http://tcpharyana.gov. in
To
1. Base Exports Pvt. Ltd.,
BTVS Buildwell Pvt. Ltd., ,..._
Adson Software Pvt. Ltd.,
Ornamental Realtors Pvt. Ltd.,
Aspirant Builders Pvt. Ltd., ....._
Clo Base Exports Pvt. Ltd.
sea No. 6-8, Sector 9D, .........
1•1 ft 2nd Floor, Madhya Marg,
2.
Chandigarh.
Mahindra Homes Pvt. Ltd.
Mahindra Towers, 5th Floor,
Dr. G.M. Bhosale Marg, Warlim,
Mumbal-400018.
-,...._
3. IREO Pvt. Ltd.

.......
A-11, First Floor, Neetl Bagh,
New Delhi.
~-½) ......
Memo No. LC-1042·11-JE (VA)-2019/ Dated:
jk
......
Subject: Permission for Joint development rights ft Marketing rights for an
area measuring 6. 79375 acres with Mahindra Homes J?.yt. Ltd. ft IREO ......
Pvt. Ltd. out of total licenced area measuring 11.55 acres w .r.t.
license no. 16 of 2008 dated 31 .01. 2008 granted for development of ,.....,
Group Housing Colony In the revenue estate of village Behrampur,
Sector-59, Gurugram Manesar Urbon Complex.
Ref. This office memo dated 16.01.2018 ft your request received on

12.04.2018 &. 09.05.2019.
Your request to grant permission for Joint development rights ft

.........
Marketing rights for an area measuring 6. 79375 acres with Mahindra Homes Pvt. Ltd. ft
IREO Pvt. Ltd. out of total licenced area measuring 17.55 acre~ w.r.t. license no. 16 of .....
2008 dated 31.01.2008 granted for development of Group Housing Colony in the
revenue estate of village Behrampur, Sector-59, Gurugram has been considered after
receipt of balance administrative charges, fresh Development Agreement ft receipts of
an undertakings and is allowed subject to the following terms a conditions:·
1. That the land ownin_g company shall not trarasfer the land for which license
issued to you to the said companies and not violate any condition of license. ,...,,_
z. Base Exports Pvt. Ltd. shall be solely responsible for compliance of all the
provisions of the Haryana Development and Regulation of Urban Area Act, 1975
&. Rules, 1976, and also abide by all the terms ft conditions of license as well as
agreements executed at the time of grant of license till the final completion of
the project. "'
3. In case of any advertisement for the sale of flats, in the said colony, the name .......
of licensee must be prominently displ::iyed.
(K. Makrand Pandurang, IAS)

Director,
Town tt country Pt:inning ,.......
y11aryana, Chandigarh
, I
.......
&
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409

SCO No. 71-75, Sector-l 7C, Chandigarh, Website; tcpharyana.gov.in
Phone: 0172-2549349; email: tcpharyana3@gmail.com
ORDERS
The orders earlier issued vide endst. No. 11333-11345 dated 29/06/ 2015 has
been further deliberated upon and reconsidered. It has been observed that it may not be
appropriate to categorise a licenced project to be in violation of section 7(i) of Haryana
Development and Regulation of Urban Areas Act, 1975, only on account of the marketing/
development being undertaken by a third party other than the original developer provided
the licencee submits its compliances in accordance with the policy parameters dated
18.02.2015.
Accordingly, the orders earlier issued vide endst. No. 11333-11345 dated
29/06/2015 are hereby withdrawn. However, it shall be imperative to recover administrative .......
charges in all such cases coming to the notice of the Department where such "Change in
Beneficial Interest" has taken place, either before or after 18.02.2015, without obtaining prior
permission of the DGTCP, Hr.
541-
(Arun Kumar Gupta) ,...._
Dated: 31-03-2016 Director General,
Place: Chandigarh Town and Country Planning,
Haryana, Chandigarh.
Endst. No. PF-SlA/2016/ 6583-6590 Dated: 01/04/2016
A copy is forwarded to following for information and necessary action: -

1. Senior Town Planner (M), Haryana, Chandigarh.
2. Senior Town Planner, Gurgaon/ Faridabad/Rohtak/ P,mchkula/ Hisar.
3. Senior Town Planner(E&V), Haryana, Chandigarh. .....,
4. All District Town Planners of the State.
5. All District Town Planners (HQ).
6. All Assistant Town Planners (HQ).
7. Accounts Officer, 0/o DGTCP, Haryana, Chandigarh
8. Website Administrator with the request to host the orders on Departmental website
for information of general public/ developers.
Sd/-
(Rajesh Kaushik) .......
Assistant Town Planner (HQ)
Directorate Town & Country Planning
Haryana, Chandigarh
......
.....
......
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410
Notes forming part of the financials statements
Amount In Rs. (Lakh1 unless otherwise stated)
Year ended Ye■rended

31 March. 2019 31 Mardi. 201s
21 Revenue from operations
Rupees · Rupees
"
Sale of product
i. Income from property devefopment 35,576.32 20,280.05
ii. Management fee 621.53 410.00
HI. Income from transfer of development rights 343.94
other operating revenues

I. Transfer charges 47.77 61.85
II. Other Incidental Income received from customers 4.61 507.80
21,2st.10
22 other income
I. Income from investment [measured at fair value]* 92.44 25.36
ii. Provision for doubtful advances written back (net) 50.00 45.00
iii. Gain on sale of fixed assets (net) 1.23
Iv. Rental Income 13.09 19.74
v. other non-operating Income 0.36 18.89
vi. Interest Income on:
Delayed payment from customers 114.80 272.40
Deposits 349.43 290.52
Loan given to body corporate 408.88 258.09
Others 73.06
1,030.23 1,003,06 I"""\
*Includes fair valuatlon ·lmpact of Rs. 92.44 (31 March, 2018: Rs. 25.36).
23 Decrease/ {Increase) In Projects In Progress (PIP)
Opening balance 348,049.80 337,243.48

67,912.21
Opening adjustment In PIP due to adoption of Ind AS 115 (see note 39)
Less: Development rights rescinded (95.28) ( 16.62)
(A) 415,866.73 337,226.86
Closing balance (B) 406;148.51 348 049.80

Decrease/ (Increase) in Inventories (A-8} 9, 18.22 c1o;b2.ta>
Notes:
(i) Closing inventory includes Rs 1,341.70 (Previous year: Rs.
1,192.05) pertaining to costs of clubs which the Company
intends to sell to third parties.
(II) The agrregate amount of costs incurred and profit

recognised (less recognised losses) to date for Project in
Progress
Cost incurred 209,457.31 183,150.68

Profit margin 55,855.37 47,306.53
24 Employee benefit expenses
I. Salaries, wages and bonus 3,696.72 5,239.76

ii. Contribution to provident fund 194.49 234.75
Iii. Gratuity expenses (refer note 29) 116.75 128.89
Iv. Compensated absences 24.02 80.84
v. Staff welfare expenses 151.75 136,53
~465.11) ~3.57)
)' Less: Cost allocated to other companies
3, 18.62 5, 7.20
,....,
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,...,,
411
Ireo Private U mlted
Amount In Ra. ( Lakh, unless otherwlN st ated)
Year ended Year 111nded

31 March, 2019 31 March, 201s
Rupees Rupees
2 5 Depreciation a!'ld amortization exoense
Depreciation of property, plant and equipments (refer 695.33 785.23

I. note 3)
II. Amortization of intangible asstes (refer note 4) 11.11 145.50
706.44 9 30,73
.---..
26 finance costs
I. Interest on
a. Borrowings from banks and flnanclal Institution 19,271.02 17,194.74
b. Debentures 1,703.14 6,768.45 ....._
C. Liability component of non-convertible redeemable 4,019.60 3,495.30
preference shares
d. Development charges payable to regulatory authorities 541.09 722.28 ,,....,_
e. Bonds 9,028.92 2,039.03
f. Others see.so 206.65
II. Unwinding of security deposit received
Ill . Loan prepayment charoes
8,224.42
43137iUt
5,217.26
396.98
H 1iMo.i9
--
Note:
Finance cost Includes borrowing cost lnventorlsed during the
year of Rs. 7,363.62 (31 March, 2018: Rs. 4,530.89}.
2 ,: Other exDenN■
I. Rent 14 2.32 145.84

II. Rates and taxes 1,040.00 217.11
Ill. Office malntalnce 36.05 178.25
iv. Repair and maintenance - Plant and Machinery 31.90 65.60
v. Repair and Maintenance - Others 1,170.44 1,484.90
vi. Power and Fuel 272.28 388.39
vii. Travelli ng and conveyance• 204.07 414.27
viii. Communication expenses 89.95 126.34
Ix. Printing and stationery 26.82 72.21
x. Bank charges 86.37 239.63 ..........
xi. Architect and design fee 49.58 1,567.36
xii . Government dues and license fees 1,683.70 859.72
xiii. Staff recruitment expenses 4 .62 8.99
xiv. Legal and professional charges 1,284.87 1,305.29
xv. Security Charoes 268.55 347.08
xvi. Claim and compensation expense 16,686.52 840.30
xvii. Guest house expenses 25.03 28.86
xviii. Advertisement and business promotion expenses 149.90 180.20 ........
xix. Membership and subscription 4.88 28.55
xxl. Loss on sale of fixed assets 0.09 ........
xxll. Brokerage and commission on sales 720.86 676. 17
xxlv. Corporate social responsibility expense 34.35
xxv. Advances written o!T 0.35 757.57
xxvl. Capital expenses written off 34.30
xxvll. Provision for doubtful advances 487.05
xxvlll. Exchange differences (net} 10.09 2.44
xxlx. Miscellaneous expenses 112.80 227.12
24,636.23 10,213.63
Less: Cost allocated to other companies {190.96) ~316.43)
24,445.27 , , 97.20
• Includes Rs. 83.04 (31 March, 2018 : Rs . 128.56) towards

Minimum Lease Payments (M.L.P.} for vehicles taken on .-.,,
cancellable ooeratina lease.
** Remuneration to auditor:
I. Statutory audit 12.00 12.00
11. Group reporting 5.00
111. Reimbursement of expenses 0.93
12.9 3 17.00
........
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412
lno Grace R.eala:.eh Prlvat• Umltacl
No._ farming p■rt of th• flna nclal s tatements .......
Y•randad Y•rendecl
11 a.venue from ope111tlon■

.......
31 Man:h,2019
........
11 M■ ~2011
........
Reil estate operations 227,830,817 796,048,759
Other opar■tlng revenue

a. Interest on delayed payment from customer1 362,~ 2,537,947
b. Transfer charges
2D,ii9,411 ,••,.,11
96 011
,,.....
11 Other lncoma
a, Interest Income on barik deposits 7,272,425 6,801,128
b, Provl1lons no longer required written beck '3,380,097
c. Other non-operating Income 744
i\113,211 7,00!
17 (lncr■■N) In Projac::bl In prog,....
Opening balance (A) 9,653,625,088 8,914,857,285 .......,

Closing balance* (B) 10,688,081,608 9,653,625,088
(lnCNIIN) In Projecte In Pl"OllnlN (A-■) -""'
*Includes Rs.- 93,674,048 (31 March, 2018: Rs 75,689,921) pertaining to com of dub, In respect: of
which the Company has entered Into an agreement'to .sell with a third party.
Note: The a11regatie ■maunt ~ c:aata lncufflld ■nd protlla recognlNcl (leN remgnlNd ..._)
to date for Project In Prog .....
Colt Incurred 3,451,101,695 3,309,450,632

Profit margin 1,490,284,700 1,414,462,040
11 l!mP'°"9 INtn.nt apen._

a. Salaries and bonus 38,888,433 36,338,080 ,-...
b. Contribution to provident f\lnd 1,861,173 1,760,327
c. Gratuity expense 1,318,293 1,114,743
d. Compensated absences 952,054 378,498
e. Staff' wel1'11n1 expenses 1,576,501 992,997
Colt transferred from related party (refer note 27) 7 420,687 ........
--7'· i:z,6i7,i4I e 14,
17i770'i77
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413
lreo Grace Rultech Prfv■te Umlted
Not• foanlm1 ~tirt of th• t1n•nd1I atatem1nts
YMrendad Yurendad
31 March, 2011 31 March. 2011 ,,...,,
RuPNa ltupaaa
19 Pln■n~c:aat■
~,
a. Interest on
- Loans from banks and nnandal Institution 451,234,989 252,790,796
- Development charges payable to regulatory authorities 118,954,805 112,425,132
- Otht!rs 13,394,266 11,240,545 r,
b, Bank charges 2,150,742 36,823,663
c. Anclllary cost of arranging borrowings 61,875,000
15111 71-1,lib 471i111,1li
-
Nola:
Finance cost lndudes borrowing cost lnventortsed during the year of Rs. 450,674,333 (31 March,
2018: Rs. 303,798,779),
20 oth•~upen-
II. Government dues and license fees 21,995,520 46,732,160
b; Architect and dalgn fee 5,347,316 13,522,883
c. Legal and profealonal charges 30,766,135 17,668,210
d. Advertisement and buslne.- promotion expenHS 9,8150,592 3,436,453
e. Rates and taxes 13,325,469 8915,914 ....,
f. Rent 14,230,545 12,881,370
g. Office Maintenance 5,547,800 2,067,'742
h. Insurance charges 4,448,912 6,468,768 ,,-.,
I. Power and Fuel 507,002 5,420
j, Travelllng and conveyance 252,423 987,095 --,
le. Communication expenses 519,754 515,485
,. Printing and stationery 190,718 221,866
m, Sea.lrlty ExpenMS 7,824,277 11,374,610
n. Clalms and compensation 40,549,220 1,387,792
0, Remuneration to auditors (refer note below) 273,284 250,000 "'
p. Brokerage and commission on sales 12,220,503 27,076,883
q. CSR expenditure 3,000,000 ,....,_
r. Provision for doubtful advances (net) 528,727 217,540,678
s. Exchange loss (net) 1,333,713 24,086
t. Mlscellaneous expenses 130,434
r-1. Cost transfarred l'rom related party (refer note 27) 3,156. 269
i7!zi7!17i
9,8611555
37!01!,404
Nate:
Rllmunaratlon to audltore
a. Statutory audit fee 250,000 250,000
b. Reimbursement of expenses 23, 284
271, 214 ZI0,000
,...,
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414
Irco Victory Valley Private Llmlt.!d
NQtcs (ormtna part of the finaocJaf statements
fAmo\lnt In Ruoees)
1:nu1rpr,ses owne.u or
slgniflc:antly lnfluenc.e-d by key
Nature otTransactlon Holdlna comoanv Fellow Subsldiarv °'
manaaement rsonnel or their Total
2018-19 2011-18 2018-19 2017-18 2018-19 2017-18 2018•19 2017-18
Transactions during the vear

fl"lanagemant services
received
• Irt!O Pnvat.e Umrted . . - . 42,480, 000 42,480,000 42,480,000 42,480,000
Total
1i:><penscs 1ncurrea on oenan
- - - . 42 480 000 42.480 000 42,480.000 42.....0 .000
>
• of tile Comp,1ny by
-l re-o Private Limited
- lttO Grace Realtech Private
- . . 599,96S 479,047 599,965 479,047
Umlteo . . . 2,25.7,090 . 2,257,090 .

Total . . . . 2 857,055 479 047 2 857.055 479 047
A mount rece,veCI from
customer on our behalf by
- lrco Grace Rt!altech Private
Limited . . . . 9,138, 553 . 9,138,553 -
Total . . . 9.138 553 9.138 553 .
Amount received rrom
• lrco Pnvate l.lml ted . . 36,200,000 289,622,516 36,200,000 289,622,516
• l reo Grace Realtech Prtvate
Umtteo . . . . 250,000 250,000 .
Total . . . . 36 450.000 289 622, 5115 36,450,000 289 622,516
Amount paid lo
- lrco Prtvate Limited . . . 192,079,256 480,500,058 192,079,256 480,500,058
Tot.ii . . . - 192 079,256 480 500 058 192 079 256 480,500058
Balance uu.....1'1a1ng as at
ye11r end:
Interest accrued but not due
on deluintures
- Natamcsh Umited• . . 51,022,870 51,022,870 . . 51,022,870 51,022,870
Debcntutts
• Innopolnt Umfted* "' 971,864,200 971,864,200 . . . 971-,864,200 971,864,200
Adv11nces rec:elVllble
- trco Prfv.atc Limited . . . 611,931,205 456,651,914 61 1,931,205 456,651,914
,
- treo Graci! Realtech Pnvate
Limited . . . 35,881,812 2~.2.S0,349 35,88 1,812 29,250,349
Amount P•yable
- I reo P1Wal e Um lted . . . 77,760,000 38,SSO,OOO n ,760,ooo 38,880,000
Total 971,864.200 971, 864 200 51.022,870 51.022,870 72S 573AJ17 524,782.263 1.748,460,087 1,547,669,333 0,,□
-'.J. - \JAL,.r-)
..... .
,_ "'<
\I'
\
Notes:
"The debenrurehold., has wJivC!d th!! interest for the Clln'l!MC and previous years. y C.}
:;. ;-i
\ ~
0 " ·
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) ) ) )
i ) ) ) ) ) ) ) )
415 ....,,
!reo Rfffdences Comoanv Private Limit ed

Note• !ormlna part of t he flnanclal statements
Year ended Year e nded
31 March1 2019 3 1 March1 2018
Rupeu Rupeu
18 Other Income
a. I nterest Income on bank deposits 11390,039 1,2871508

1,390,0 39 1, 287,508
11 Deer•■■• / (IncreHe ) In Project• In progren

Opening balance l (A) 4,106,119,662 3,509,486,134
Less; Expenses transferred to related party (see note below) (77,224,753}
Closing balance ( B) 4,404,720,817 41106,119,662
...,,.
DecreaM / (Increase) In ProJeC:U In prooreas CA·B) i zH,601,155} (873,858, 28 1}
Note:
~ Expenses allocated to Ireo Hospitality Company Private Limited pertaining to
~ :::-6 earlier vears.
20 Employee benefits expen•e
-..
a. Salaries and bonus 85,271,028 88,577,485
b. Contribution to provident fund 4,230,708 4,438,238
c. Gratuity expenses 1,108,938 760,822 ---..
d. Compensated absences 1,022,409 1,286,292
e. Staff welfare expenses 1,881,738 1,901,593
f. Salary cost allocated from related party (refer note 29} 4 454 238 3,350,042 "'"'
97,969,059 100,314,472
7> Less: Salary cost allocated to related party
21 Fina nce colts

~25~~lf:J;21
2! 1 7
~24!957~:~
8, s,,
....,
....._
11.I nterest on
• Loan from related party 6,872,409 35,285,885
- Inter - corporate deposit 15,780,822
- qeve1opment charges payable to regulatory authorities 215,966 233,370 ........
a. I nterest on delayed payment of statutory dues 1,809,095 3,299,980
24,878, 292 38,819.23 5
.......
Note:
The above finance cost includes Rs. 215,966 (March 31, 2018 Rs.
233,370} lnventorlzed In accordance with the provisions of Accounting
Standard 16.
,,..~AN ~ ....
.,.
~-· ;i\
(/) (1
" ,.
q. !
~ . .:,
1
-:i_ r,"'or-.cO-c.-: ~
~
,....,_
.......
.......
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416 .......
Ireo Hospitality Company Private Limited

Notes forming part of the financial statements
Year ended Year ended

31 March, 2019 31 March, 2018
Rs. / Lakh Rs. / Lakh
22 Other income
,.-.,
a. I nterest Income on
- Loan given to related party 68.72 352.86 ....
- Deposits with banks 151.28 16.80
b. Other non-operat ing income 13.26
233.26 369.66
23 Employee benefits expense
Salaries and bonus 1.16 1.26

Staff welfare expenses 9. 16 7 . 11
Cost allocated from Third party 30. 11 40 .25
40.43 48.62
--.
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417
Jreo Private Unlittd

,a
t{g1a (!n1ncl1l s11111u1•ll fsir tl11 l:S!" end~ rtlac,h ~J . :1011
Flnanclnl Assets • Loans. at an1ortl1ed cost (Currenl)

Current
--
M•rch 31, 201? Morch 31, 2016 Aprll 01 0 2015
Loan to body corporata•

llll•l Clll,l ffil,l --
Unsecured. considored aood 164,151 ,441
........
Torti 164151 441
•Lotn to body COIJ)Oratc carries an in1ere1t rate of t4•/4 p,1, 1r1d i, repayable on demand.
7 OtkerHHlf ....._
Non•currcnt Current
March 31 1 1017 March 3 1, l0U April 01, 2015 March31,201? March 31, 1016 Aprlt0J,1015
IB!·l (!!•.) (Rs,) (RJ.) ~-l
Advances for punhaH or land
!'"·l
'
Unsecured, considered good
Advaneu for purchue of development right,

(A)
100,000
100000
100000
100000
350000
350000 ---
Unsecured, consideccd good (refer 11011 2 below) 1,318,125,335 1,784,035,531 616,608,816
Doubtful 442 793 743 446 135 79) 629890693
1,760,919,078 2,230,171,324 1,246,499,509
Less: Provision (or doubtful advances (442,793,743) (446,135,793) (629,890,693)
(Bl 1318125335 I 784 035 531 6 16608 816
Capltal advances
Vntccurcd, considered aood 27 563 457 33459967 22 832 908
(CJ 27 56] -~7 33 ◄59 967 22 832 908
Stcurlly deposits
Unsecured, considered good S 982 652 9239200 46 8922$0
(D) 5,982,6S2 9~39,200 46,892,250 .....,_
Advaaca recoverable
Un,ccured, cONidered good 663,047,495 771,513,◄ l3 ?57,494,646
Doul>tl\JI I 99715'1 612159 I 099104
665,044,649 772,12S,S72 758,593,750
Less: Provision for doubtful advances !1 19971154! (612,159) (1,099,104)
Other 1dY1nct1
(D) 663 047 495 771S13413 757494646 ,...._
Unsecured, considered good
Prepaid expenses 185,289,199 234,639,489 357,720,860
Balance with starutory aulhoriliea: (refu note I below) 117,178,807 SZ,◄23,561 103,745,677
C~s11ion recoverable (refer note 43) 29,929,949 19,929,949
(E) 332 397 955 316992 999 461 466 537

Total (A+B+C+D+E) 2715631◄57 331459.967 12,831,908 1~ 1916531437 2 1111 1111 1143 11e12r!uiao
Notc.s:
I. Balance with statutory authorities includes Rs. 15,000,000 (March 31, 2016: RJ. 1.5,000,000~April OJ. 2015: Rs. I5,000,000) paid ■s an advance against service tax liability.
Management is hopeful that the said affl04.llt wowd be adjusted 1gain1t future lax liability and 1ccordin91y no provision hat been made for tho s,me.
2. The Company has entered into arrangements with its various special purpose vehicles (SPVs) for development o( real estalo projects. Pursuant 10 these arrangements, Company has
--
provided inlere,r frto advances to tlieso SPVs for acquirina development righu in lond ptrcels 10 be purchased lhrousJ, these SPY,. The SPY, have I\Jrthcr odvanccd a sum Rs. or
889,506,185 (Mon:h 31, 2016: R,, 803,805,002; April 01, 2015: RJ. 793,930,888) nel of amount written off Rs. 103,128,200 (M11<h 31 , 2016: R,, 95,796,950; April 01, 2015: Nil) 10
various parties for purchase of land parcels. The third parties to whom monies have been advanced are yet to identify the target land parcels. Out of lhe aforesaid advances. management,
bosod on ilsasscnment, has provided a sum of RJ. 4'12,?93,743 (Morch JI, 2016: Rs. 446,135,793; April 01, 2015: tu. 629,890,693) u doublful advance and for lhorcmainins 1moun1, it
is confident of ultimate tdjustment/rccovcry of these balances and has treated them as aood of recovery.
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418
Ii·•o Private Limited

Notes to financial statements for jhe ye•r ended March 31, 2017
ll Revenue from ope1·allons

March 31, 2017 March 31, 2016
/Rs.) IRs.l
Sale of products
Income from property development 3,763,039,319 S,251,064,262
Income from joint development agreement 3,572,289,360
Management fee 60,000,000 210,000,000
,-..
Other operating revenues
Enhanced compensation received from compulsorily acquisition (refer note 43) 734,937,015
. ·~ Transfer charges 9,368,996 27,766,069
Other incidental income received from customers 49,512,259 30,829,386
3,881,91.0,574 9,826,886,092
12 Other income
March 31, 2017 March 31, 2016
fR••> /Rs,)
Interest income on
Enhanced compensation received (refer note 43) 542,325,484
Delayed payment from customers 43,929,379 30,695,693
Deposits 26,169,233 30,678,368
Loan given to body corporate 17,390,490
Others 1,023,234 l,970,S24
Provision for doubtful advances written back (net) t7,388,JS3
Gain on sale of f1Xed assets (net) 493,495 -....
Exchange gain (net) 97,595
Rental income 1,200,000
Other non-operating income 4,943,366 3,775,671
112,537,550 6091543,335
--
23 Decrease/ (Increase) In Projects In Pro11ress
March 31, 1017 March 31, 1016
11q.1 /Rs.)
Opening balance 35,733,253,911 36,161,434,857
Less: Development rights rescinded (21.S41,2l8) (40,639,259)
(A) 35,711 ,712,693 36.)20,79S,S98
Closing balance• (B) 3S,457,165,988 3S,733,2S3,91 I
Decrease/ (Increase) In Inventories (A-Bl 254,546,705 387,541,687
Notes:
(i) Closing project in progress 3S,457,165,988 35,733,253,911

Assets classified as held for distribution (refer note 41) {1.743,729.438)
Total 33,713,436,550 35,733,253,911
(ii) The aggregate amount of costs incurred and profit! recognised (less recognised losses) to date for Project in Progress
March 31, 2017 March 31, 2016

(Rs,) (Rs,)
Cost incurred 23,463,441,126 20,312,312,204
Profit margin 10,108,922,091 9,572,535,755
(iii)
• Includes Rs 92,339,ISI (March 31, 2016: Rs. 85,284,486) pertaining lo costs ofclubs which the Company intends to sell to third parties.
l4 Employee benefit expenses

March 31, 2017 March 3 1, 2016
llq,) rRs.}
Salaries, wages and bonus 585,677,522 86S,478,556
Contribution to provident fund 29,784,526 38,963,415
Gratuity expenses (refer note 29) 17,446,584 23,549,637
Staff welfare expenses 36,930,681 63,077,206
Less: Cost allocated to other companies (157,014,644) (211,710,842)
!ill ,824,669 779,357,912
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419
Jreo Private Limited
Notes to tbcfinaaclalflatrmm~_(or the year ~died l\l•rcb 31~ 2017
n:1.11S:1c:tJom d WVH' tlle - - : Amoant in I<s..

Holding Ce>111p111)' Fellow S•bsidiaries Key Maugemeat Pt:not1ael R.datives or Ke, Mauc,etlcllt Eatities ander Jig:oifieaat Su:llridiariu Tott.I
Ptrsoaat:f: iaflumce ofkey m:aniipmea.t
penoancl
2016-17 2015-16 2016-17 201S-16 2016-17 2015-16 2016-17 2015-16 2016-17 2015-16 2016-17 2015-16 2016-17 2015-16
M.allag'Clllcnt servitci rendered
-? (excludes service tu)

- Ireo Vie!ON Vallov l'>t. Ltd. • • • 60,000,000 210,000 000 60 000,000 210,000.000
Tot>I - • • 60,000,000 210,000,000 60,000.000 210,000,000
Interest p:aid OD debeatiarts (rder
notes 2 aDd 3 below)
t..mg,: Limited • - 201,70',2,J • • • 201,706,2'1 •
S<thos Limited · - 203,11'-4.U • • 203,ll.9,44' •
IreolnvcslmentHoldin•IDLtd. 3,133.32' • • • - • • 3,133.n, _
Total 3,133.32' - 404.125,735 • • 407.959.061 •
Interest paid on n.o.-coavtmblt
redttm11ble prcf'crence 1han:r (nfa-
note Sl
Ireo Victory Valley Privue Limited • • • 10,167.,53 - 10,167,953 •
Ireo lllvesanentHol"-IDLtd. 293,771,197 264.294.913 • - • • - - 293,771.197 264,294,913
Total 293,771.197 264.29-1.913 - - - 10,167,953 • 303339.150 264,294,913
➔
~pcma iuaan-ed by lbt Company
onbebli'of
-IteoFiwrivo,Pvt. Ltd. • • • - 4,'82,549 9.490,314 - 4,.ca2,SC9 9,490,314
-.PumaRealtot1Pvt.W. • • • • - 1,521,SSl l ,6S0,711 1,5l8,IS2 1,650,711
-Proud Buildwell Pvt. Ltd. - • • • • • • 95',m • 956,'99
-WiodornlnhhomePvt.Ltd. • • • - 762,752 • 762,752 •
• Iteo Wamfu>nt Pvt Ltd. • • • S,0'6,922 8,712,113 1,096,'22 8,782,113
• ltto Gnice Realledl Pvt. Ltd. • • • • • 9',315.679 254,128,825 '9,385,679 254,128,125
• Ireo Hospitality Co. Pvt. Ltd. • • • • • - 13,231,013 7,212,562 13,281,013 7,282,562
- Ireo llesid<D«S Co. Pvt. Ltd. • • • 9-"40.883 • 9,'40,113
·F,;,J,Builde<edl P.i. Ltd. • • • • • 7,753,820 21,937,459 7,753,120 21,987,459
• Elite Township Pvt Lid. • • • 6,456,237 6,456,237
• Sunflo-Realtechl'vt. Ltd. • • • 1,140.171 5,030,691 1.240.178 5.030,698
Total • • • • 160.1&5.814 308-352681 li>O,ISS.184 308.352,681
Amoant paid by the Com pa Dy on
~ bebal!or
• lreo Victor)' Valley Pvt Ud • • • • 1,801,175 1.•1•,393 - 1,101,175 1,474,393
• lreo Gn<:e Realtedl Pvt. Ltd. • • • • • 6.550,039 6,231,241 - 6.550.039 6,231.248
TolAI • • • • 1.351314 7 705 641 • • 1.351.915 7,705,641
Expemes iaaamd by 04 OU' ~ht.If
"-? - ho Ftvaivcr Pvt. Ltd.
- Ireo Ho..,;-,:... ca. Pvt. Ltd.
.. •
• •
-
•
-
• •
131
6'.596
- 131
66,596
Total • • • • • 66.727 • - • 66,727 •
Lase~ i,aid to
• Jai Bbanl • -• rRTm • - • • 691.935 • • • • 691335 •
Total • • • 6'1,935 • • 6'1335
-----::> Lease rmt c:brged fro•

> -Ireo llesideoc:es Co. Pvt. Ltd.
-Elite Townsbin Pvt. Ltd.
•
-
•
•
•
• •
600,000
. 600,000
• - 600,000
i>00.000 •
Tot>I • • • • 1.200,000 1.200,000
A.dlout pt.id for Ii.abilities
---7 tn.asfernd froai
- Ireo 0.- Reallecb Pvt. Ltd. • - • • • • • 200,000 • • 100,000
-Ireo Wate<frontPvt. Lid. • • • • • • • 1,003,490 • 1,003,490
- Ireo Residcnc<s Co. Pvt. Ltd. • • • • - • 285.507 - 285,507
Total • • • • • 185.St7 1,203.490 2SS.S07 1.203 490
AllloHt received &om automen by
~
tbt Comp.ury on bcbJf or
-IreoVi-·Vall~PvtLtd • • • • • • 1,990,000 • • 1.990.000
Total • • • • • • • 1.990.000 • 1,990 000
Amount reaivtd from cu,tomen on.
our belliiU' by
~ -lreoV'tCIOryVdeyPvtLtd • • - • • • 1,246,869 • - 8,246,869
p Lr,-..
I ...---::=-0
\$\\
• Ireo - Realtedl P,;t. L<d.
.1reow11a1n>ntPv1. Ltd. -
•
•
•
•
•
• I/✓" 0 I:' 1 r" .. 6',J4',625
2.250.650
• •
•
'9,946,625
2,2so.,so
Tot•l - - • • , .~·~::-:":""!""~...
41..,-~'-·::~"..'.:--j§C'::
-
/ - L...\<CJ~)'- •
(~U 1- ""'.' - TI.197.275 8,246169 - - 11.197.275 8,246,869
\; i,,
.t ~- :(
-~!~) (
'~~\:\?
c C·\',
) ,......: •
-,
~-;-~·o~-.;-...- a. './-:) ~ ---

&
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J ) ) ) ) ) ) ) ) ) ) ) )
J )
420
lrco Private Limited
Notn to financial statements for the Y••r •ndetl Morch 31, 2018
20 Revenue fro m operations

J\brch JI. 2018 March 31, 2017
(R>.l (R1.l
Sale of product
Income from propeny je,elopmtm 20,280.05
~ - ~a_nagement fee 3YS.00
Other operating revenues
,...._
Transfer charges 6! 8~ 9369
Other incidcr.tal income receivr.a from cuslomers SIJ7.80 495. 12
li.244.70
21 Other income
.,...._
March Jl, 2018 Mnrch JI, 2017
fR,.) (Rs.;
f11come from investment imcasurec. 111 fair value)• 25.36

Net gan,~CY.>S on sale of investmentS ".l.O~
Provision for douhlful advances written back (net) 45.uO 248.88
Goin on sale of fixed a~scts (nci) 4 9j
Rental income 19.74 12.0~
Other non-optrating incomt i8.89 49.43 --.._
Interest income on
Delayed payment from customers 272 4!! 439.29
Deposits 24S.6(J 26t.69
Loan given 10 body ~orporat~ 258 39 173.90
Others ,;,Oo 10.26
958. 14 I ,200.44
"Includes fan vaiuation impact of Rs. 25.36 (March 31, 2017: Rs. Ntl).
22 Decrease / (lncrcuc) In PrujccU in Protn:»

March 31. 2018 1\tarcb 31, 2017
[Rs.; (lu.)
Opening balance 337,243.4~ 357,332.54

Add: Project in progress acquired in amalgamatmn l00b6
L~ss Development nghts cesciPded ; :6.621 ,78.49)
Less: Transfcrrec 10 other cc,mparnes ;17,4.P.29 I
(t,) 337,226.St' 339.917.42
Closing baiancc• (B) 34~.u~.~o 317,243.48
Dccrrase / (Increase) in invenlorin (A-8) (10,822.94! 2 67l94

1
Nottt:
l be aggregate amount of costs incurred and profits rccogr.ise<l lless recognised lo;scs) 10 date f-:,r i>,vJect in f'rogrcss
1\1arch 31. 2018 March JI, 2017 ......
{Ro.) (Rs.)
Cost incurred 251,062.89 234,634 41
Profit margin I04.264.6.~ 102.795.25
ii • Includes Rs I, 192.05 (Previous year: Rs. 923.39) pertaining to <'OSts of dubs which tnt (,ornpany intends ,o seii to ,hird ;,arties
23 Employee bcnen1 exnensH

----
March 31 . 2018 ~!Rrcn 31, 2017
(Rs.) (Rs.)
Selanes, wages and bonus 5,239.44 5,920 97
Contribution to providen, n.md 234.n 297 85
C,ratuity e.l(pcnses (refer note 28) 128 89 !74 4 7
Compensated absences 80.84 (64. 19)
Staff welfare expenses ·.36.53 369.J0
Less: Cost allocated le other companies (73357 ) (1,570.15) ~
5,128.25
.......
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421
..-,,
lrco Private Limited
Notes to financial statements for the year ended March 31, 2018
Amount in Rs. (lakh unless, otherwise stated)
24 Other expenses
March 31, 2018 March 31, 2017
(Rs,} {Rs.l
Rent 145.84 166.64

191.75 711.85 ,,....._
Rates and taxes
Office maintaincc 178.25 146.14
Repair & Maintenance-Plant & Machinery 65.60 75.53
Repair & Maintenance-Others 1,484.90 1,643.i l
Power and fuei 38~.39 449.59
Travelling and conveyance• 414.27 532.21
Communication expenses 126.34 195.92
Printing and stationery 72.21 109.38 ,......
Architect and design fee l,567.36 1;882.44
Government dues and license fees 859.72 988.13
StafTrecruitment expenses 8.99 11.90
Legal and professional charges 1,282.05 1,276.87
414.71 ,,..._
Security Charges 347.08
Claim and compensation expense 840.30 119.18
Guest house expenses 28.86 32.23
Advertisement and business promotion expenses 180.17 138.08
Membership and subscription 28.55 39.01
Remuneration to auditors •• 17.00 40.97
Loss on sale of fixed assets ().09
Brokerage and commission on sales 676.17 764.15
Donation 0.50
Corporate social responsibiiity expense 34.35 86.14
Advances writttn off 757.57
Provision for diminution in vaiue of investments 21.00
Exchange differences (neti• .. 2.44 2.35
Miscellaneous expenses 227.!2 3.67
-~ Less: Cost allocated to other companies (3, 6.43) (746.24) 4:
9,608.94 9,105.46
• Includes Rs. 128.56 (March 31, 2017 Rs. 182.73) towards Minimum Lease Payments (M.L.P) for vehicies
taken on cancel!able :.,perating lease.
March 31, 2018 March 31. 2017

!Rs,) {Rs.)
•• As auditor:
Statutory audit 12.UO 27.65
Group reporting 5.00 11.50
Reimbursement of expenses 1.82
17.00 40.97
--..,
••• includes loss on derivatives instruments measured al FVTPL of Rs. Nil (March 3 I, 2017: 286.71}
2S Depreciation and amortization expense
March 31, 2018 March JI, 2017

(Rs.} {Rs.)
Depreciation of property, plant and equipments (refer note 3) 785.23 883.51

Amortization of intangib:.: asstes (refer note 4) 145.50 167.70
930.73 1,051.21
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422
Ireo Private Umited
Amount In Rs. CLakh. unless otheiwlse stated) r
Year ended Year ended
31 March. 2012 31 March. 201a
· Rupees
Sele of product
I, Income from property devefopment 35,576.32 20,280.05
II. Management fee 621.53 410.00
Ill. Income from transfer of development rights 343.94
other operating revenues

I. Transfer charges 47.77 61.85
II. Other incidental Income_received from customers 4.61 507.80
36,594.17 21,2S!Uo ,-...
22 Other Income
I.
Income from Investment [measured at fair value]* 92.44 25.36
Provision for doubtful advances written back (net)
ii. 50.00 45.00
Gain on sale of fixed assets (net)
Ill. 1.23
-.:>;>iv. Rent81 Income 13,09 19,74
v. other non-operating Income 0.36 18.89
vi. Interest income on:
?
Delayed payment from customers
Deposits
114,80
349.43
272.40
290.52
~ loan given to body corporate 408.88 258.09
Others· 73.06
1,031'-23 1,003.06
*Includes fair valuation ·lmpact of Rs. 92.44 (31 March, 2018: Rs. 25.36).
,.....
23 Decrease / (lncteHe) In Projects In Progress (PIP)
Opening balance 348,049.80 337,243.48

""'
--..
67,912 .21
Opening adjustment In PIP due to adoption of Ind AS 115 (see note 39)
~
- _::7
Less: Development rights rescinded
(A)
(95.28) (16.62) -4:::-
415,866.73 337,226.86
Closing balance (B) 406,148.51 348 049.80

Decrease/ (Increase) in Inventories (A-8) 9, 11.22 (10,122.94)
Notes:
Closing Inventory Includes Rs 1,341.70 (Previous year: Rs .
~
..-")
.-/'
1,192.05) pertaining to costs of clubs which the Company
intends to sell to third parties.
(II) The agrregate amount of costs Incurred and proflt

recognised (less recognised losses) to date for Project in
Progress
Cost incurred 209,457.31 1-83, 150.68 ......._

Profit margin 55,855.37 47,306.53
i. Salaries, wages and bonus 3,696.72 5,239.76

II, Contribution to provident fund 194.49 234.75
Iii. Gratuity expenses (refer note 29) 116.75 128.89
Iv. Compensated absences 24.02 80,84 ,....,
v. Staff welfare expenses 151.75 136,53
less: Cost allocated to other companies ~465.11) ~33.57)-4----
3, 18.62 s, 7.20
........_
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423
Ireo Private Umlted
NotN forming part of the flnanclals statements
Amount In Ra. ( Lakh. unle■a otherwln atatad}
Year anded Year ended

31 March, 2011 31 March. 2011
Rupees Rupees
.....,
25 DeDN1datlon •!'Id amortization expense
Depreciation of property, plant and equipments (refer 695.33 785.23

I. note 3)
II. Amortization of Intangible asstes (refer note 4) 11.11 145.50
706,44 930 ,73 ......
26 l'lnance costs
,,-...,
i. Interest on
a·. Borrowings from banks and financial Institution 19,271.02 17,194.74
b. Debentures 1,703.14 6,768.45
C. Llablllty component of non-convertible redeemable 4,019.60 3,495 ..30
preference shares
d. Development charges payable to regulatory authorities
e . Bonds
541.09
9,028.92
722.28
2,039.03
---
f. Others 588.50 206.65
II. Unwinding of security deposit received 8,224.42 5,217.26
Ill . Loan prepayment charges 396.98
43 1376.69 36,040.69 -.
Note:
Finance cost Includes borrowing cost lnventorlsed during the
year of Rs. 7,363 .62 (31 March, 2018: Rs. 4,530.89).
27 Other expenses
I. Rent 142.32 145.84

II. Rates and taxes 1,040.00 217.11
Ill. Office malntalnce 36.05 178.25
Iv. Repair and maintenance - Plant and Machinery 31.90 65.60
v. Repair and Maintenance - Others 1,170.44 1,484.90
vi. Power and Fuel 272.28 388.39 .,,....,
vii. Travelling and conveyance• 204.07 414.27
viii. Communication expenses 89.95 126.34
Ix. Printing and stationery 26.82 72.21
x. Bank charges 86.37 239 .63
xi. Architect and design fee 49.58 1,567.36
xii. Government dues and license fees 1,683.70 859.72
xiii. Staff recruitment expenses 4 .62 8.99
xiv. Legal and professional charges 1,284.87 l,305..29
xv. Security Charges 268.55 347.08
xvi. Claim and compensation expense 16,686.52 840.30
xvii. Guest house expenses 25.03 28.86
xviii. Advertisement and business promotion expenses 149.90 180.20
xix. Membership and subscription 4 .88 28.55
xxl. Loss on sale of fixed assets 0.09
xxll. Brokerage and commission on sales 720.86 676.17
xxlv. Corporate social responslblllty expense 34.35
xxv. Advances written off 0.35 757.57
xxvl. capttal expenses written off 34.30
xxvll. Provision l'or doubtful advances 487.05
xxvlll. Exchange differences (net) 10.09 2.44
xxlx. Miscellaneous expenses 112.80 227.12
24,636.23 10,213.63
---;:!' Less: Cost allocated to other companies (190.96)
24,445.27
(316.43)
9,897,2 0 ~
• Includes Rs. 83.04 (31 March, 2018: Rs. 128.56) towards
Minimum Lease Payments (M.L.P.) for vehicles taken on
cancellable ooeratina lease.
•• Remuneration to auditor:
I. Statutory audit 12.00 12.00
11. Group reportlno 5 .00
Ill. Relmbl!rsement of expenses 0.93
oo~ ....
12.93 17.00
~ \J i
UJ c::, ,,....
~ .
I *
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424
,,....._
lreo Grace RNltec:h Private Umlted

Not• forming lllll of lh• ftn■nd■I -■temtnts
Y-■rendad Y•rendad
1t Pln■n~COllla
31 March, 2019
RUPNa ........
11 N■rch, 2011 r--
'
a. Interest on
- Loans from banks and flnandal Institution 451,234,989 252,790,796
- Development charges payable to regulatory authorities 118,954,805 112,425,132 ,,._
- Othtlrs 13,394,266 11,240,545
b. Bank charges 2,150,742 36,823,663
cl)
c. Anclllary a>St of arranging borrowings 61,875,000 e- ""
511, 734,80:1 471, 111,131 ,,.-
Note: .......
Finance cost lndudes borrowing cost lnventorised durtng the year of Rs. 450,674,333 (31 March,
2018: Rs. 303,798,779).
~
20 Otherexpen-
a. Government dues and llcense fees 21,995,520 46,732,160
b; Architect and design fH 5,347,316 13,522,883
c. LAgal and protealonal charges 30,766,135 17,668,210
d. Advertisement and buslne.- promotion expensa 9,860,592 3,436,453
e. Rates and tax• 13,325,469 896,914 '"'
f. Rent 14,230,545 12,881,370
g. Office Maintenance 5,547,800 2,067,742
h. Insurance charges 4,448,912 6,468,768
I. Power and Fuel 507,002 5,420
j. Travelling and conveyance 252,423 987,095
k. communication expenses 519,754 515,485 ,...,
I. Printing and stationery 190,718 221,866
m, SeQ.lrtty Expenses 7,824,277 11,374,610
n. Claims and compensation 40,549,220 1,387,792 ......
0, Remuneration to auditors (refer note below) 273,284 250,000
p. Brokerage and commission on sales 12,220,503 27,076,883
q. CSR ex~ltUre 3,000,000
r. Provision for doubtful advances (net) 528,727 217,540,678 ,...
5 . Exchange loss (net) 1,333,713 24,086
Ml10ellaneou1 expenses 130,434
~ - Cost transferred rrom releted party (refer note 27) 3i5i 179
1,~ 7 269 9161,555
17! l!,404
.......
Nole:
Ramuneratlon to auclltor9
a. Statutory audit fee 250,000 250,000
b. Reimbursement of expenses 23,284
271,2114 210,000
,.....
.......
......
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425
lreo Grace R•■ltech Prlvata Umlted
Notell to ftn■ncl■I atatementa·tor the ear ended 31 March 2019
land. As per the arrangements, the Company would be developlng the project and Owner
1 earlier would be getting a speclfled percentage of .the sale proceeds from the project
and the owner 2 would be entitled to a speclfled bullt-up area of the project.
.....,.
Pursuant to said arrangement, Owner ·1, had been advanced a sum of Rs. 390,000,000
(31 March, 2018: Rs. 390,000,000) In earlier years. During the year ended 3~ March,
2017, the said balance was adjusted by agreed share of revenue of Rs. 190,364,864
calculated as per th.en underlying agreement. During the previous year, an addendum to ,..,.
earlier agreement was entered with the Owner 1 and according to the revised terms,
Instead of share In sales proceeds of the project, an ldentl"ed parcel of llcensed land of .......
equal size on larQely slmllar FAR wlll now be given to the Owner 1 as agreed In earlier
years. Accordingly, the· revenue of Rs. 190,364,864 which was credited to the account of
owner 1 was reversed and the amount of advance paid of Rs. 390,000,000 has been
treated as Interest free refundable security deposit. ·
Further, the Owner 2 had been provided with a refundable security deposit of Rs.
350,000,000 (31 March, 2018~ Rs. 350,000,000). The company had bought back certain
bullt-up area In an earlier year, out of the total bullt-up area which the Owner 2 was
entitled to, for a consideration of Rs. 1,400,000,000 and the same has been treated as
cost •of development rights and thus Included as cost of project In progress.
c) The company had entered Into a joint development agreement with Ireo Flverlver
Private Umlted (IFPL), a related party till April 29, 2016, for developlng a group housing
.project In Panchkula, Haryana on the land owned by them by acquiring the development
rfghts on the said land. As ~r the arrangement, the Company was required to develop
specl"c land parcels of the project against an Interest free refundable sea.irfty deposit of '"""
Rs. 1,000,ooo,ooo. As per Agreement, the IFPL was entitled for specl"ed built-up area of
the project and the aforesaid security deposit was to be refunded back to the Company
on the culmlnatlon of the above transactlon. The Company had paid Rs.• 830,500,000 tlll ,,....
March 31; 2017 as an Interest free refundable security deposit under the said agreement.
considering the market lnstablllty, slgnl"cant approvals & executions delays on the part
of IFPL and thus resultlng Into lnablllty to repay the aforesaid security deposit, during the
year ended March 31, 2017, the Board of Directors of the company had resolved a
settlement agreement with IFPL. consequently, both the parties had mutually agreed on
March 28, 2017, whereby a sum of Rs. 150,000,000 was agreed to be returned back
through six monthly Installments starting from Aprll Ist, 2018 against refundable security
deposit ·of Rs. 830,SOO,OOO and the Company had agreed to write off balance amount of
Rs. 680,500,000. Based on the said arrangement, an amount of Rs 150,000,000 was
treated as recoverable and dlsclosed as advances and the balance amount of Rs.·
680,500,000 was written off and dlsclosed as an exc:eptlonal Item In the Statement of
Profit and Loss during the year ended March 31, 2017. During the previous year, because .....,.
of sluggish markets sentiments & considering serious cash flow situations of IFPL, an
addendum to the settlement agreement was entered and according to which settlement
amount of Rs. 150,000,000 shall be now be received In 30 equated monthly Installment
starting from 01.10.2019 along with •Interest 012% p.a. payable In case of default.
ou·rtng the current year the company has also further advanced Rs. 528,727 (31 March
31, 2018: 72,540,678) to stabllse operations of the Company. However, considering
sluggish markets sentiments, the management has considered recoverablllty of such
advance as doubtful and has made full provision of Rs. 223,069,405 as at 31 March, ,.....,.
2019 (31 March, 2018: 222,540,678}.
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426
lreo Grace Rcaltcch Private Limited
Notes to financil1I statements fo r the year ended March 31, 2018

March 31, 2018 March 31, 2017
(Rs.) ·. · (Rs.)
Real estate operations 796,048,759 4,039,965,442
Other operating revenue

Interest on delayed payment from customers 2,537,947 10,683,015
, . Transfer charges 96,011 194,367
_ , fncome from forfeiture on cancellation of units 41,037,398
798,682,717 4,091,880,222
16 Other income
March 31, 2018 March 31, 2017
(Rs.) (Rs.)
Interest income on bank deposits 6,801,128 7,340,115 ,,.....

Other non-operating income 201,700
,,..,
7,002,828 7,340,115
17 Decrease/ (Increase) in ProJects in progress

March 31, 2018 March 31, 2017
(Rs.) (Rs.)
Opening balance (A) 8,914,857,285 9,293,339,331 ,,...

Closing balance• (B) 9,653,625,088 8,914,857,285
Dccrcase/(lncrease) in Projects in progress (A-B) (738,767,803) 378,482,046
*Includes Rs. 75,689,921 (March 31, 2017: Rs 12,015,916) pertaining to costs of club, in respect of which the Company has
- 0 entered into an agreement to sell with a third party.
Note: The aggregate amount of costs incurred and profits recognised (less recognised losses) to date for Project in
Progress
March 31, 2018 March 31, 2017
(Rs.) (Rs.)
Cost incurred 3,309,450,632 2,907,232,010
Profit margin 1,414,462,040 1,018,902,566
March 31, 2018 . March 31, 201 7

(Rs.) (Rs.)
Salaries and bonus 36,338,080 30,236,107

Contribution to provident fund 1,760,327 1,258,756
Gratuity expense 1, 114,743 170,749
Compensated absences 378,498 648,641
Staff welfare expenses 992,997 912,269
~ Cost transferred from related party (refer note 27) 17,770,277 67,765,528
,....,_
58,354,922 100,992,050
,,......_
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427
lreo Grace Rcaltech Private Limited
.,...,_
19 Finance costs
March 31, 2018 March 31., 2017

(Rs.) (Rs.)
Interest on
Loans from banks and financial institution 252,790,796 201,038,813
Development charges payable to regulatory authorities 112,425,132 I 00,962,895
Others 11,240,545 12,550,910
Bank charges 36,823,663 14,695,664
~ A ncillary cost of arranging borrowings 61,875,000
475,155,136 329,248,282
Note: Includes borrowing cost inventorised during the year of Rs. 303,798,779 (March 31, 2017: Rs.
245,622,879).
.......
20 Other expenses
March 31, 2018 March 31, 2017
(Rs.) (Rs.)
,,....
Government dues and license fees 46,732,160 15,:436,520
Architect and design fee 13,522,883 15,002,984
Legal and professional charges 17,668,210 41,715,306
Advertisement and business promotion expenses 3,436,453 20,461,613
Rates and taxes 896,914 725,510
Rent 12,881,370 3,788,446
Oflicc Maintenance 2,067,742 1,038,265
Insurance charges 6,468,768 5,120,434
Power and Fuel 5,420 ,,......
Travelling and conveyance 987,095 1,351,537
Communication expenses 515,485 418,392
Printing and stationery 221,866 284,266
Security Expenses 11,374,610 7,807,893
Claims and compensation 1,387,792
Remuneration to auditors (refer details below) 250,000 907,800
Loss on sale of property, plant and equipment 3,992
Brokerage and commission on sales 27,076,883 118,685,409
CSR expenditure 3,000,000
Advances writ1en off 1,833
Provision for doubtful advances (net) 217,540,678 34,500,000
Exchange loss (net) 24,086
Miscellaneous expenses 130,434 228,033
...-:, Cost transferred from related party (refer note 27) 9,861,555 3 1,620,151
376,050,404 299,098,384
Remuneration to auditors
March 31, 2018 March31,2017
(Rs.) (Rs.)
As auditor:
Statutory audit 250,000 460,000
Other services ' 395,000
Reimbursement of expenses · 52,800
250,000 907,800
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,-..
428
lreo Grace Realtech Private Limited
Notes to financial statements for the year ended Much 31, 2017
15 Revenue from operAtions

March 31, 2017 March 31, 2016
(Rs.) (Rs.)
Real estate operations 4,039,965,442
Other operating revenue

Interest on delayed payment from customers 10,683,015 5,323,475
~ Transfer charges 194,367 469,082
. . . . Income from forfeiture on cancellation of units 41,037,398
,-..
4,091,880,222 5,792,557
16 Other income
March 31, 2017 March 31, 2016
(Rs.) (Rs.)
Reversal of Government dues and licence fees of previous year• 1,095,337,174

Reversal of interest expense of previous years on development charges• 82,812,150
Interest income on bank deposits 7,340,115 11,405,845
Other non--operating income 72,000
7,340,115 1,189,627,169
•refer note 31
17 Decrease/ (Increase) in Projects in progress

March 31, 2017 March 31, 2016
(Rs.) (Rs.)
Opening balance (A) 9,293,339,331 7,638,065,550 ,.....,,_
Closing balance• (B) 8,914,857,285 9,293.339,331
Decrease/(lncrease) in Projects in progress (A-8) 378,482,046 (1,655,273,78 1)
*Includes Rs 12,015,916 (March 31, 2016: Rs 7,650,096) pertaining to costs of club which the Company intends to sell to a third
party. "-
Note: The aggregate amount of costs incurred and profits recognised (less recognised losses) to date for Project in Progress
M1trch 31, 2017 M11rch 31, 2016

(Rs.) (Rs.)
Cost incurred 2,907,232,010
Profit margin 1,018,902,566
Much 31, 2017 March 31, 2016

(Rs.) (Rs.)
Salaries and bonus 30,236,107 103,827
Contribution to provident fund 1,258,756
Gratuity expense 170,749
Compensated absences 648,641
Staff welfare expenses 912,268
~ ost transferred from related party (refer note 30) 67,765,528 178,967,416 "
100,992,050 179,071,243
,.....
(, k ,,...._,
,,....
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429
lreo Grace Realtech Private Limited i_
I
h
19 Other expenses I[-,
March 31, 2017 March 31, 2016
(Rs.) (Rs.)
Government dues and license fees 15,436,520 825,000

Architect and design fee 15,002,984 71,539,115
Legal and professional charges 41,715,306 17,610,554 ,.__
Adve1tisement and business promotion expenses 20,461,613 2,404,709
Rates and taxes 725,510 2,766,251
Rent 3,788,446 1,343,008
Office Maintenance 1,038,265 844,409
Insurance charges 5,120,434 2,841,371
Travelling and conveyance 1,351,537 1,374,932
Communication expenses 418,392 46,088
Printing and stationery 284,266 344,030
Security Expenses 7,807,893 3,931,575
Remuneration to auditors (refer details below) 907,800 731,000
Loss on sale of fixed assets 3,992
Brokerage and commission on sales 118,685,409 1,324,227
Donation 25,000
...,.,
Advances written off 1,833
Provision for doubtful advances (net)• 34,500,000
Exchange loss (net) 23,481
Miscellaneous expenses 228,035 736,244
Cost transferred from related party (refer note 30) 31,620,151 70,556,401
~
299,098,386 179,267,395
•net of advances written off of Nil (March 31 , 2016: Rs. I 0,000,000)
Remuneration to auditors
March 31, 2017 March 31, 2016
(Rs.) (Rs.)
As auditor:
Statutory audit 460,000 400,000
Other services 395,000 300,000
Reimbursement of expenses 52,800 31,000 ,....._
907,800 731,000
20 Depreciation and amortization expense
March 31, 2017 March 31, 2016

(Rs.) (Rs.)
Depreciation of property, plant and equipment 1,988,084 1,901,934
1,988,084 1,901,934
.......
---.
,,.......
&
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430
......
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........
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'""'
....,_
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.,_1. t...
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431 -
.,...._
AND ......
: .. · ·.:
<?Iobal Estate, a -firm having its office at E-47/2, .Phase-ll, Okhla lnd~striai ·A.r~a~ Del~i'~~.:
110020, represented by Mr. furan Singh, authorized ~ign~tory, hereinafter,
'
-c:;~Hed tfie
. . . . .. .
·:
. .. :
"Purchaser" (which
.
expression ·shall unless repugnant to . the contex~
. ' . .
:~r .~eanirti·-
. . ~- '
mean and include its representati~es,- administrators, successors iri. in~erest~_-as,sigris;"·. -----
nominees) of the SECOND PART. ..
. ... . . .
'.
. : '
WHEREAS the Seller is/are the absolute owner and in actual physical po·~·session of_·. .
agricultural land bearing Khewat/Khata No. 164i l89, bearing Rect; Nq..-: 12, Kila··
Nos. 3/1(0-4), 4(8-0), 5(8-0), 6(8-0), 15(8-0), kitte 5, land measuring °J2 Kanai .4
• ' • • 'l • • \ •
Marla to the extent of 32/644 share (Sunita 1/644 share, Dheeraj, Deepfilc, Beena; ·
, . . . ·. '• . : :
Varsha all four 31/644 share in equal ·share) admeasuring to 1 Kfµlal 11 :Marla, i.e. :
- ,
0.2 Acres and Khewat/Khata No. 5/18, 69/83, Rect. No. 12, Killa:Nos ..7.(8'-0), 14(8;; ·
12,956 '!fi • • " T
0), kitte 2, land measuring 16 .Kanai O Marla to the extent of 1/20 snare (Silitita
. ..
1/320-
. . ~
share, Dheeraj, Deepak, Beenu, Varsha all four 15/320 share in eq~al share)
admeasuring to O Kanai 16 Marla i.e. 0.1 acres, Total ~hare of all ~e khewats::com~s:
to 2 Kanai 8 Marla i.e. 0.3 acres, situated in the revenue .estate .of Village ·
Dhumaspur, Tehsil & District Gurgaon, as per Jamabandi for the year 2003-2004
read with Mutations (hereinafter referred to as the "said Land") _a nd_·no . per~on other . .
that) the owner/ Seller has any right, title or interest in the said land-an_d the:·~aid land::
I
is duly recorded i.n the Jrabandi in the f?.ame of the S~-l~er. ,....._
.. ;~•-:~. ~ .., -~ .< .
-·. \ .,· .. ., .: ·. ·-~..
. '
,•. · ....
.......
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....,
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,..
'
- 432
~
-.
---
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~
t
547
-
---
--,,
,....._
gfhno11 HARYANA 399986

....._
BETWEEN
. 'I
Smt. Sunita widow of Dha~lr ~d~:1«aster Dheeraj, Master Deepak both
0
minor sons of -and Kumarl,:11.een:!f., ~~. Varsha both ~ o r daugbt~ra of

. ·... .,,
Dharan;iblr, all minor.a.. tJ)tQ~Ol ~t_µ.,_ ~ o~er ·a nd court guardian Smt.·
., Swiita, duly ap~lnte,d . c.~µ,r:t 'P~il!l.~:b.i ~e 6_ontblc Court of Sh. Raj
• I •· •
,,...., KlUJlar Ya:dav, · ·Guar:dnul.•({lUlg~~; G"1:P~A, vlde lts order dated 09.Q3.201 l
in case ·no. 2 ~ 8 dated ll.1-~ ~0-ll>, all residents of Villagc--_~n;igarh Dhani,
Badshalipurj Dlstt. G'lll'gli'oJi -l l~d J.a>)d-opfir af village Dhumaspur, Tehsil &
Distt. ·Gurgao~ hereinafter cailc::tl't-h¢
. I
·•seller.-, (whic¥ expression shall unless
repugnant to the meacl.ng or c.on:.te~. ~et-eof be -de~med to mean and include
anifi~·ees)
his /thdr 1egal heirs, successors in.:iJit.drest, legal tepresent~
·
~ f. ~
~i,
y·
"" of the ONE PART. ~ - ( ~ ~ - ;)· -;. : :
. I
,--
. .
.
\
~• l \ J
.--;
,J.\\
JI
,,..., > , • 0 ( __· 'iSJ'
( ·~ ~i _,., _t.,~ --- ,
~ fssued Under 2
,...._ -------~ R. T. I. Act. 2005·
&
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433
549
AND
- M/s Global Estate Private Limited, a company incorporated under the .,

provisions of the Companies Act, 1956 and having Its registered office at
,,.._ E-47/2, Phase-JI, Okhlalndustrial Arca, Dclhi-110020, represented by Mr.
Puran Singh, authorized signatory of the company, hereinafter called the
•Purchaser" (which expression shall unless repugnant to the context or
meaning mean and include its representatives, administrator s, successors in
,,,--,.
interest, assigns . nominees) of the SECOND PART.
WHE:i~J~AS th: Seller is/are the absolute owner and in actual physical
possession of agricultural land bearing Khewat/Khata No. 164/189, bearing
,,....
Rect. No. 12. Kila Nos. 3/ l{O-~j. 4(&-0), 5(8-0), 6(8-0), 15(8-0), kitte 5, land
measuring 32 Kane! 4 Ma:da to the ~ent qf 32/644 share (Sunita 1/644
share; Dheeraj, Deepak) Seen:a, V~1d1a all four 31/644 share in equal share)
r'
admea_suring to l Kahal 12· Marl.it, i,:e. o.~ ~CT,CS::and Khewat/Khata No. 5/ 18,
69/83 , Rect. No. 12, .lrola ~ .- 7,f8-0J, l4(a"'oJ, ~t;te 2, iand measuring 16
,,..... Kana! o M.~ _-1~~? ~q!ir.e ·(S:unita 1_132ofshare, D h ~--,..
to the-. eJtt~nt--:<5!
De·epruc, Beena, Varshb. all foo/ •l:&/~20 in equal share) ad.measu~4-o ~_!__ t,,, -.
SM.I"C·
~~ 16 Marla te. o.1 ·aore$, To~ ~hare .ofaU. the khewats comes to t,K:anaJ. ~
0
' 1;,
Matla i.e . 0.3 aerts:, ,situated in the. I'.ev.enue estate of Village D , rri\spu{
•. I • I ,
~
'? •
'
I ....
• Teh~il & Diettjct "Gurgaon., as _
p er..JQiilaban;di' for the year 2003-2004 iM'd, ·th ~ J.> , C
Mu~tiQjls (hereinafter rd«tredto,.~ ~ !~~-Land•) and no person o : . _ ~.;,_:,
..... the owner / Seller ha:s any right; titl~ ·or int~st in the !Said land and · Gq
,.... land is duly recorded in tb:eJ'amabandi, in Ul,e name of the· S~'r- . ,
,.- l
..
-
,,,....
Issued Under 3
R.T, 1. Act. 2005
&
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434
---...
----.
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436
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437 .,.....
i
l
This Deed of Sale is entered into at Gur~ou on thin :N'-" tlCly o( AUGUST 'JO 10.
. BET\VF;EN ----
'
I
l
0
Malkhan -Rainlaulwn-r - Chnnd-rapal - Baljcct s n:i of Surjl\ :.on ofllcta-;1111 14/ ~
Share) and Bin:nder - Su.render sons nutl Smt. kurcsh Dovl Jeughtc r Atul :hot.
vati Devi widow of Late Dhatambir son of suLn (1/ 6 Shnro) nll raslltc,u:c or
Vill. Kndarpur, Tchsil Sohna, Dlstt. Ourgaon, H~ryttnn, ht:rcinofir.r rcfc:rrmJ to M
th~ 'SELLERS', (\vhich c.~rcssion shall u111esJ repugnmH to U1c me:mtng o r
I
contc.'<t hereof be deemed to mean nnd include hls/their lcgnl hclnl. ~u ~o~~on,· 111
0 interest, legal reprc~entatives and nominees) of th/ ONE PART.
AND j
~
M/5 GLOBAL ESTATE, a Company incorpo 1tcd and r.-!gistered under the \
provisions of the Companies Act, 1956 und hm•ig its Registered Office nl 0 ·2~l,
ASHOK VIHAR, NEW DELHI-110052 rcprcsentef hy Sh. Girlrl\l S/o Sh. Lakh1mt
R/o A-15, Sushant Lok-III, Gurgnon, Hiary:Ltrn, authorized siHm\lory of the
company, h_e:,reinafter called the 'PURCHASER' (which cxprc:.sion :ihnU \1t1lem1
rel='.~~~..,_\~i~;§~_?.~text or meaning thereof me I nnd include its rcp1cc;e11tativcr1,
admiriistratoi•s, successors in interest, ussigus, n mine~:;) o f the SECOND PART.
WHEREAS the SELLERS(s) is/are the absolut . OW'Ilt.'r and iu nctuol phyni~al
possession of agriculturul land bellrlng lthcwat IK.h11tn No. 8/21, Rcctnnr,!~.~~
12, Killa Nos. 18/2(3-0), 19(3-18), 22(1·1.6), ~3(7-ll)t Re_c~. No, 13, tttha No . ._
3(~-8) total kita 5 land admeasu~~: ~ann~ •. ~3 M:,~las (2.706 Acrc:.i)
\ situated in the revenue estate of ~~c- ·011um:tspur, Tchsil and Dis trict
,· . .,. :~- I ... · ......,
Gmgaon, Haryana as per the Juniabandl YcaJ 2003-2004 1 1-'ard Dndnr No. :J
and Mutation No. 969 (hereinafter referred to n the "Srud l...'.i°~d") and 110 p crn.:>11
.other than the owner / SELLERS have any right~ title or interest in the s:.ud land
a.'1d the said land is duly recorded in the Jrun:ibru~cti in the nrunc of the SELl...EHS.
AND WHEREAS the: SELLERS(s) for his/thl!ir nbs lute fnmily jJ~cesti\,)!._i:1 intcndmg
r • J t ) "" I •1' •• 'l ' ,",
to sell this land. The land under sale is not profit ble for C\ilt1vatioh''u-i1?~~rch ::u;cr
has offered a very handsome sale price and so the sale is for. tl1c 1.len"c;i o f U1c-
. . , ,·, \
family and the sale consideration will be u sed fo the ul~atc ·b1neftt of lh~jfr1m1ly
purchase of other land. , .· · / .. / •
~' ~ ,I r<:.J:m '': :: ' -

670J~1; . {~?1/ •
-/',,, . ..
.... .l.
Scanned by CamScanner
......
&
TRUE COPY
1/16/23, 3:24 PM Gmail - Fwd: Ref. No. PR/81/2020- DD/108/2020 - In the matter of complaint made by CA Vinesh Jain (M.No.087701) M/s SN Oh ...
438
Gmail ANNEXURE A-4
Ananya Garg <garg.ananya98@gmail.com>
Fwd: Ref. No. PR/81/2020- DD/108/2020 - In the matter of complaint made by CA

Vinesh Jain (M.No.087701) M/s SN Dhawan & Co. LLP, Delhi, against you, under
Section 21 of the Chartered Accountants Act, 1949
Nikita Jain <nikita.j@legesworld.com> Tue, Dec 20, 2022 at 2:20 PM
To: "ananya.g@legesworld.com" <ananya.g@legesworld.com>, Ananya Garg <garg.ananya98@gmail.com>
Get Outlook for Android
From: Ramesh Sanka <rameshsanka60@gmail.com>

Sent: Friday, 25 November, 2022, 6:26 pm
To: Adv Zeba Khair Delhi <zeba@legesworld.com>; Shivambika Zeba Office
<shivambikasinha@gmail.com>; Nimita Kaul Zeba Office <nimita.kaul@gmail.com>; Nikita Jain Zeba Office
<nikita.j@legesworld.com>
Subject: Fwd: Ref. No PR/81/2020- DD/108/2020 - In the matter of complaint made by CA Vinesh Jain
(M.No.087701) M/s S N Dhawan & Co. LLP, Delhi, against you, under Section 21 of the Chartered
Accountants Act, 1949
- - Forwarded message ---------

Date: Tue, 13 Sept 2022 at 12:56
Subject: Re: Ref. No. PR/81/2020- DD/108/2020 - In the matter of complaint made by CA Vinesh Jain (M.No.087701) M/s
S N Dhawan & Co. LLP, Delhi, against you, under Section 21 of the Chartered Accountants Act, 1949
To: disc@icai.in <disc@icai.in>
Cc: amit.threja@icai.in <amit.threja@icai.in>
Respected Amit Threja ji

Please help.
Polite reminder ... matter pending from 11th May 2022 onwards and
overall for last 2.5 years from the time complaint has been filed by me.
regds
On Tue, 21 Jun 2022 at 10:37, Ramesh Sanka <rameshsanka60@gmail.com> wrote:
To
kind Attn ... Sri Amit Thareja ji
Respected Sir,
Thanks for the reply you have provided.
POLITE REMINDER as more than 40 days have passed.
regds
On Thu, 12 May 2022 at 17:24, disc@icai.in <disc@icai.in> wrote:
&
TRUE COPY
https://mail.google.com/mail/u/0/?ik=690cd364 76&view=pt&search=all&permmsgid=msg-f%3A 1752722337133772644&simpl=msg-f%3A1752722337 ... 1/4
1/16/23, 3:24 PM Gmail - Fwd: Ref. No. PR/81/2020- DD/108/2020 - In the matter of complaint made by CA Vinesh Jain (M.No.087701) M/s SN Oh ...
Kind Attention:- Shri Ramesh Sanka

439
Dear Sir,
Please refer to your trailing mail on the captioned subject.
This is to inform you that on completion of the prescribed stages under the Chartered
Accountants (Procedures of Investigations of Professional and Other Misconduct and Conduct of
Cases) Rules, 2007, the matter is now under process for doing the needful in terms of Rule 9 of the
aforesaid Rules.
At this stage, since the matter is under examination in terms of the Rules cited above, any
further communication in this regard would be sent only subject to the decision taken by the
appropriate authority in this matter.
Please be assured that the matter is receiving attention as mentioned above.
Regards
CA. Amit Threja
Deputy Secretary
Disciplinary Directorate
Phone No.: 30210634
e-mail:disc@icai.in

Sent: Wednesday, May 11, 2022 4:34 PM
To: disc@icai.in <disc@icai.in>; ajayjain@icai.in <ajayjain@icai.in>
Subject: Re: PR 81/2020-DD/108/2020 dt 8 july 2020 ... NOW PAID THRO AXIS BANK
Kind Attention .. Mr.Amit Thareja
Respected Sir,
I just now spoke to you on the phone. Can you please help me by giving the status
of this complaint.
Best regds
On Sat, 23Apr 2022 at 12:16, Ramesh Sanka <rameshsanka60@gmail.com> wrote:

Respected Sirs,
1) I have submitted my Rejoinder on 18th August 2020 related to the reply filed by
CA Vinesh Jain.(PR 81/2020-DD/108/2020). It is almost 20 months that the reply
has been filed by me. This fraud / wrong disclosures by CA Vinesh Jain were
primarily related to the evasion of Indirect and Direct Taxes by lreo. ICAI
has not yet sent me the Prima Facie Opinion. Request you to expedite the
same as it is pending for almost 20 months.
I
&
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1/16/23, 3:24 PM Gmail - Fwd: Ref. No. PR/81/2020- DD/108/2020 - In the matter of complaint made by CA Vinesh Jain (M.No.087701) M/s SN Oh . ..
I have paid thro Axis bank ans payment receipts are enclosed herewith. 440
Iii Scan - REJOINDER - VINESH JAIN.pdf
Regds
Ramesh Sanka
9810609241
- - Forwarded message ---------
Date: Wed, 15 Jul 2020 at 13:42
Subject: Re: PR 81/2020-DD/108/2020 dt 8 july 2020 ... NOW PAID THRO AXIS BANK
To: ICAI DISCIPLINE <disc@icai.in>
Respected Sir,
Correct files attached now. Apologies for the inconvinience.
On Wed, Jul 15, 2020 at 12:41 PM Ramesh Sanka <rameshsanka60@gmail.com> wrote:

Respected Sir,
1) Pl find enclosed your letter returning my DD due to Covid-19 reasons.
2) I HAVE MADE PAYMENT THRO AXIS BANK & RECEIPT IS ENCLOSED

HERE
I
Best Regards
RAMESH SANKA
Best Regards
RAMESH SANKA
Best Regards
RAMESH SANKA
9810609241
Best Regards
RAMESH SANKA
9810609241
Best Regards
RAMESH SANKA
9810609241
Best Regards
RAMESH SANKA
&
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1/16/23, 3:24 PM Gmail - Fwd: Ref. No. PR/81/2020- DD/108/2020 - In the matter of complaint made by CA Vinesh Jain (M.No.087701) M/s SN Oh . ..
441
9810609241
Best Regards
RAMESH SANKA
9810609241
&
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ANNEXURE A-5
442
HomeExpress ExclusivePandora Papers: Homebuyers, investors high and dry, Ireo’s Goyal moved $77 million to
offshore trust
Pandora Papers: Homebuyers,

investors high and dry, Ireo’s Goyal
moved $77 million to offshore trust
Many homebuyers, having lost hope of getting their apartments, are approaching courts,
seeking possession or refund. So are marquee foreign investors such as Axon Capital and
Children’s Fund Foundation in courts overseas for returns on hundreds of millions of
dollars pumped into the group’s projects.
Written by P Vaidyanathan Iyer | New Delhi |

Updated: October 12, 2021 12:57:55 pm
Lalit Goyal
Observing that “builders only understand the colour of money or a jail term,” the Supreme Court
bench of Justices DY Chandrachud and MR Shah held in contempt an IREO Group company on
August 19 for failing to comply with its order directing refund of money to a homebuyer.
&
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443
Many homebuyers, having lost hope of getting their apartments, are approaching courts, seeking
possession or refund. So are marquee foreign investors such as Axon Capital and Children’s Fund
Foundation in courts overseas for returns on hundreds of millions of dollars pumped into the
group’s projects. The IREO Group flagship IREO Private Limited is reeling in losses — Rs 500
crore in 2018-19.
But group co-founder Lalit Goyal, whose sister is married to BJP leader Sudhanshu Mittal, had
moved assets, investments, and shareholdings, worth an estimated $77 million, to an offshore trust
structure which included four entities registered in the British Virgin Islands much before the group
got into trouble, reveal internal documents of Trident Trust, a global corporate services company.
According to these documents, Goyal — his residence address is mentioned as Marina Bay
Residences, 18 Marina Boulevard, #45-08, Singapore — had set up the Oak Veneer Trust in tax
haven Guernsey with Standard Chartered Trust (Guernsey) Ltd as a trustee. Goyal is the ‘Settlor’
— one who sets up or authors the trust — of Oak Veneer Trust. He and Standard Chartered Trust
(Guernsey) Ltd – by virtue of it being a trustee of Oak Veneer – are the ‘Beneficial Owners’ of the
four offshore entities, all of which were acquired either to hold property, shareholdings and
investments, or to be an ‘investment vehicle’.
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here.
The documents form part of Trident Trust’s Third-Party Introducer forms signed by a top executive
of Standard Chartered Trust (Guernsey) Ltd, the trustee of Oak Veneer Trust, in November 2016.
The Indian Express emailed queries to Lalit Goyal and the compliance officer of IREO Private Ltd
last month, but there was no response.
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Trident Trust documents which show Lalit Goyal as the Beneficial Owner of Turquoise Waters
Worldwide Limited.
444
The four offshore entities, all with registered addresses in the British Virgin Islands, are: Maple
Leaf Worldwide Limited, Madison Group Services Limited, Turquoise Waters Worldwide Limited,
and Garden Estate Worldwide Investment Limited. These four cumulatively hold assets with an
estimated value of about US $77.73 million.
In 2016, the real estate group was in the limelight after it announced a partnership with Donald J
Trump Jr’s The Trump Organization for a Rs 100-crore office tower project in Gurugram.
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ringfence wealth in secret havens
IREO Private Ltd’s latest financial reports for 2018-19 show that the company posted Rs 500 crore
losses on a turnover of Rs 376.24 crore. The total losses carried to the balance sheet stood at Rs
1,774.51 crore. Its total assets were Rs 4,505.49 crore, inventories alone accounting for Rs 4,061.48
crore. Its holding company is Mauritius-based Ireo Investment Holding III Ltd.
In February 2018, Goyal was accused by two New York-based global investment companies,
Children’s Investment Fund Foundation and Axon Partners, of “large-scale fraud”.
On March 19, 2018, The Washington Post reported that the two had “filed a criminal complaint
with New Delhi police last month alleging that the fund’s Indian managing director, Lalit Goyal,
co-founder Anurag Bhargava and others engaged in ‘large-scale fraud by ‘illegally siphoning off’
at least $147 million of investor money, although the actual sum could approach $200 million…
Police in New Delhi said they have received the complaint”.
Also Read |Pandora Papers: Kamal Nath’s son, Agusta deal key accused had offshore links
The four entities are off-the-shelf companies whose shareholders, directors and record keeping
agents are the same. The shareholders for all the four are two Guernsey-registered companies,
Nominees One Ltd and Nominees Two Ltd. The director of the four companies is Songbird Ltd,
also registered in Guernsey. Standard Chartered Trust (Guernsey) Ltd is responsible for keeping
records physically at PO Box 620, Bordeaux Court, Les Echelons, South Esplanade, St Peter Port
in Guernsey, a British Crown dependency, and the second largest of the Channel Islands. The
shareholders and the director have the same address.
Delhi News
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Drunk couple arrested for trying to enter Rashtrapati Bhavan 445
Delhi pollution: Government to hire 1,000 private CNG buses to increase strength of
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improve AQI after Nov 21
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446
Money laundering case: ED arrests

IREO’s Lalit Goyal
Goyal was produced in a special court in Panchkula on Tuesday and remanded to seven
days of ED custody.
Written by Deeptiman Tiwary | New Delhi |

Updated: November 17, 2021 3:34:08 am
Lalit Goyal, Vice Chairman and Managing Director of Ireo Group. (File)
ENFORCEMENT DIRECTORATE on Tuesday arrested Lalit Goyal, vice-chairman and managing

director of real-estate group IREO, after four days of questioning. The arrest was made in
connection with a case of money laundering registered by the agency at its Chandigarh branch on
the basis of allegations that IREO swindled funds of home buyers and its investors.
“Enforcement Directorate has arrested Lalit Goyal, Managing Director of M/s IREO Group of
companies under The Prevention of Money laundering Act, 2002 … in a case related to cheating
and siphoning of funds of Home Buyers/ Investors and Others,” the ED said in a statement.
It also made a mention of The Indian Express investigations into the Pandora Papers, which
revealed Goyal moved an estimated US$ 77 million in the form of investments, shareholding and
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property, even as home buyers and investors ran from pillar to post for their money. 447
“Investigation further reveals that Lalit Goyal is settler and named beneficiary of a Guernsey based
overseas Trust, which owns and controls entities holding assets outside India. Recent Pandora
Papers Leak has also named four entities (which are beneficially owned by Lalit Goyal) having
registered address in BVI hold assets having value more than USD 77.73 Million (Rs. 575 crore
approximately),” the ED statement said.
Following his arrest, Goyal was produced in a special court in Panchkula and remanded in seven
days of ED custody.
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Goyal was detained at IGI Airport last Thursday, based on a look out circular opened against him,
while he was preparing to board a flight to go abroad. “Since his detention at the airport, we have
been questioning him. He was appearing before ED everyday for interrogation but has been
evading questions. Since he has not been cooperating, he had to be put under arrest,” a senior ED
official said.
According to the ED, it initiated money laundering investigation on the basis of FIRs registered at
Panchkula by Haryana Police, FIR of Economic Offences Wing, Delhi Police and FIR registered at
Hauz Khas police station in Delhi against M/s IREO Private Limited, M/s IREO Five River Private
Limited, Lalit Goyal and others.
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“Modus operandi adopted by the group includes routing of funds from various entities based 448
in tax
havens countries like British Virgin Islands (BVI), Mauritius etc, diversion of funds by way of buy
back of equity shares, recording of fictitious expenses in the books of accounts, writing off project
in progress, loans and advances to sister concerns and round tripping of funds through shell
companies. Total funds involved are over Rs. 2600 crore, part of which is proceeds of crime,” the
ED said in its statement.
On November 11, 2019, Haryana police had registered the first FIR relating to the IREO group
housing project in Panchkula. The complainant had alleged fraud involving Rs 160 crore on the
construction company named IREO Five River, under offences of cheating, criminal breach of
trust, dishonesty, misappropriation of funds, forgery for the purpose of cheating, corporate and
economic offences, act of threat and criminal conspiracy with a common intention.
“Ireo Five river Pvt. Ltd. neither had license nor land in its name. The Director, Town and Country
Planning Department had not given it any approval/permission to develop the colony. The DTCP
had not also granted it permission to sell plots/flats et al to buyers and collect money from them,”
the FIR said.
The ED is also probing a Foreign Exchange Management Act (FEMA) case against the company
since 2010.
An October 12 report published in The Indian Express had revealed that Goyal had moved US $ 77
million to offshore Trusts even as homebuyers and investors had approached authorities and courts
against the company for return of their money.
The IREO Group flagship IREO Private Limited is reeling in losses — Rs 500 crore in 2018-19.
According to revelations made in The Indian Express’s Pandora Papers investigation, the group co-
founder Lalit Goyal, whose sister is married to BJP leader Sudhanshu Mittal, had moved assets,
investments, and shareholdings, worth an estimated $77 million, to an offshore trust structure
which included four entities registered in the British Virgin Islands much before the group got into
trouble. This was revealed in internal documents of Trident Trust, a global corporate services
company.
According to these documents, Goyal had provided the address of his Singapore residence and had
set up the Oak Veneer Trust in tax haven Guernsey with Standard Chartered Trust (Guernsey) Ltd
as a trustee. Goyal is the ‘Settlor’ — one who sets up or authors the trust — of Oak Veneer Trust.
He and Standard Chartered Trust (Guernsey) Ltd – by virtue of it being a trustee of Oak Veneer –
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are the ‘Beneficial Owners’ of the four offshore entities, all of which were acquired either to 449
hold
property, shareholdings and investments, or to be an ‘investment vehicle’.
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450
ANNEXURE A-6
REPORTABLE
IN THE SUPREME COURT OF INDIA

CRIMINAL ORIGINAL JURISDICTION
WRIT PETITION (Crl.) No.142 OF 2018
Ramesh Sanka …….Petitioner (s)
VERSUS
Union of India & Ors. …….Respondent(s)
JUDGMENT
Abhay Manohar Sapre, J.
1. This writ petition is filed by one Mr. Ramesh
Sanka under Article 32 of the Constitution of India
seeking for the issuance of Writ of Mandamus or any
other Writ or directions directing Respondent No.23
(CBI) to investigate the entire matter and examine all
the allegations made by the writ petitioner against

Signature Not Verified
Digitally signed by
ANITA MALHOTRA
Date: 2019.01.25
Respondent Nos.12 to 22 in accordance with law. The
16:44:11 IST
Reason:
1
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451
other reliefs claimed in clause (b) to (d) of the writ
petition are consequential to the main relief.
2. Stated concisely, the petitioner seeks the
aforementioned reliefs on following facts.
3. The petitioner is a former employee of
Respondent No.12 a Limited Company. He worked as
CEO of the said company from June 2014 till 31 st
December 2016.
4. In substance, the grievance of the writ petitioner
is against Respondent No.12. He has highlighted the
manner and the modus operandi of Respondent No.12 –
Company, in carrying out their business and financial
operations/dealings.
5. His grievance is also against the persons who are
managing the affairs of Respondent No.12 Company
and also against the Companies, individuals and the
firms with whom respondent No.12 Company is having
2
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452
their business and financial dealing/operations i.e.
(Respondent Nos.13 to 22, 24 and 25).
6. According to the writ petitioner, Respondent
No.12 – Company, through their Directors and
employees has committed several financial irregularities
in their business and financial dealing with many
Companies, firms and individuals who are having their
work places in India and abroad contrary to and in
contravention of the provisions of Several Acts/ Rules /
Regulations which have gone unnoticed despite the writ
petitioner had sent several complaints/representations
to various statutory authorities in this behalf.
7. According to the writ petitioner, all such
dealings/activities of Respondent No.12 – Company,
which he has highlighted in the writ petition has not
only caused heavy loss to the public exchequer but also
rendered the persons, who indulged in these activities,
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453
liable to face prosecution for commission of several
cognizable offences punishable under the Acts.
8. It is essentially with these background facts; the
writ petitioner has made allegations in the writ petition.
He has also filed some documents to show prima facie
that the prayer made by him in his writ petition
deserves consideration.
9. On 11.07.2018, this Court issued notice of this
writ petition confining it to the official respondents
namely, respondent Nos.7 to 11. These respondents
have filed the status report in a sealed cover. One
officialrespondent has filed the affidavit.
10. Respondent No.12 – Company, however, in the
meantime entered suo motu appearance and has filed IA
No.104447 of 2018 praying therein for dismissal of the
writ petition on legal as well as on factual grounds.
11. In substance, according to respondent No.12 –
Company, the writ petition filed by the writ petitioner
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454
under Article 32 of the Constitution deserves dismissal
on the grounds inter alia that it is not a bona fide
petition. It is contended that this writ petition is filed by
a former employee of respondent No.12 – Company to
score his personal issues and the differences qua
respondent No.12 – Company, for which some civil suits
are pending between the parties in the Civil Court: that
the writ petitioner has suppressed several material facts
in the writ petition including the fact of pendency of the
Civil Suits between them: that the writ petition is filed
with an ulterior motive at the behest of others only to
tarnish the image of respondent No.12 – Company, in
the market: that the writ petition does not involve any
issue of infraction/violation of any fundamental rights,
guaranteed to the citizens under the Constitution of
India, of the petitioners. The Respondent No.12 –
Company, has denied all such allegations made against
them by the writ petitioner as being baseless.
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455
12. The writ petitioner has countered the averments
made in the aforesaid IA by placing reliance on the
averments made in the writ petition contending that
there has been no suppression of the material facts as
alleged by respondent No.12 – Company.
13. In the meantime several persons /organizations
have suo motu filed the applications being I.A.
Nos.3739/2018, 17628485/2018, D.No.110020/2018,
160094/2018, 171501/2018, 160094/2018,
163098/2018, D. No.17594347/2018, 144019/2018,
81895/2018, 165472/2018, 163874/2018,
157884/2018, 115735/2018 and 2974/2019, seeking
therein various kinds of reliefs for them individually and
collectively against respondent No.12 – Company, in
relation to their independent dealings which they
claimed to have had with respondent No.12 – Company
and which according to them are not till date fructified
6
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456
and given to them by respondent No.12 – Company, as
agreed.
14. We have heard all the learned counsel for the
parties in support of their case.
15. Having heard the learned counsel for the parties
and keeping in view the law laid down by this Court in
the cases reported in State of Uttaranchal vs. Balwant
Singh Chaufal & Ors. [2010(3) SCC 402], K.D. Sharma
vs. Steel Authority of India Ltd. & Ors. [2008(12) SCC
481 and lastly in Arun Kumar Agrawal vs. Union of
India & Ors. [2014(2) SCCC 609], we are not inclined to
grant any relief in this writ petition.
16. At the outset, we find that the writ petitioner has
not claimed any relief in person qua respondent No.12 –
Company, in this writ petition. Even otherwise, no writ
lies under Article 32 of the Constitution at the instance
of any employee or the employer for claiming
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457
enforcement of any personal contractual rights inter se
the employee and his employer.
17. If the writ petitioner has any personal grievance
in relation to any of his contractual personal rights
flowing from any service conditions or any other
agreement with the respondent No.12 – Company, his
legal remedy lies in filing Civil Suit or take recourse to
any other civil law remedy for adjudication and
enforcement of his rights qua respondent No.12 –
Company or anyone claiming through them as the case
may be. The writ petition under Article 32 of the
Constitution is not the remedy for agitating any such
grievance.
18. It is not in dispute that the parties are already
prosecuting their grievances against each other in Civil
Court in their respective civil suits filed by them against
each other. If that be the position, the same have to be
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458
pursued by them in accordance with law against each
other.
19. So far as the raising of other grievances as set out
supra by the writ petitioner against the other
respondents are concerned, suffice it to say, this court
by order dated 11.07.2018 had issued notice to the
official respondents Nos.7 to 11. These respondents
pursuant to the notice issued have filed their respective
status report in relation to the inquiries, which is being
undertaken by them in their respective jurisdiction. We
have perused the same.
20. Needless to say depending upon the outcome of
the inquiry once it is completed by the respective official
respondents in their exclusive jurisdiction under
various Acts, the appropriate action as provided in law
will follow against all those who are found guilty.
21. Before parting, we make it clear that we have not
expressed any opinion on several factual issues alleged
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459
and denied by all the parties against each other in this
writ petition and in respective IAs.
22. This order, therefore, will not influence any
authority or the Court or ongoing inquiry or proceedings
while dealing with any issue. The same has to be dealt
with uninfluenced by this order.
23. In view of the foregoing discussion, it is not
necessary to entertain several IAs bearing
Nos.3739/2018, 17628485/2018, D.No.110020/2018,
160094/2018, 171501/2018, 160094/2018,
163098/2018, D. No.17594347/2018, 144019/2018,
81895/2018, 165472/2018, 163874/2018,
157884/2018, 115735/2018 and 2974/2019, filed by
different applicants for claiming various reliefs qua
respondent No.12 – Company, in relation to their
individual and collective grievances.
24. All such applicants would be at liberty to raise
their grievances qua respondent No.12 – Company
10
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460
whether individually or severally for adjudication of
their rights before an appropriate Judicial Forum in
accordance with law.
25. It is with these observations, we find no merit in
this writ petition, which fails and is accordingly
dismissed.
………………………………..J.
(ABHAY MANOHAR SAPRE)
..………………………………J.
(R. SUBHASH REDDY)
New Delhi,
January 25, 2019
11
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ANNEXURE A-7 461
CWP No.4144 of 2020

& four connected petitions [1]
237
IN THE HIGH COURT OF PUNJAB & HARYANA
AT CHANDIGARH
****
Date of Decision: 18th March, 2020
1. CWP No.4144 of 2020
M/s Ireo Hospitality Company Private Limited

Petitioner
Versus
Union of India and others

Respondents
2. CWP No.4506 of 2020
Ireo Victory Valley Private Limited

Petitioner
Versus

Respondents
3. CWP No.4507 of 2020
Ireo Grace Realtech Private Limited

Petitioner
Versus

Respondents
4. CWP No.4512 of 2020
Ireo Residences Company Private Limited

Petitioner
Versus

Respondents
5. CWP No.4513 of 2020

Petitioner
Versus
Union of India and others Respondents
For Subsequent orders see CM-5189-CWP-2020 Decided by HON'BLE DR. JUSTICE S. MURALIDHAR;
HON'BLE MR. JUSTICE AVNEESH JHINGAN
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CWP No.4144 of 2020

CORAM: JUSTICE S. MURALIDHAR

JUSTICE AVNEESH JHINGAN
Present: Mr. Balbir Singh, Senior Advocate with

Mr. Gajendra Maheshwari, Advocate
for the Petitioners.
Mr. Sourabh Goel, Senior Panel Counsel

for Union of India.
Ms. Amrita Garg, Advocate for

Mr. Arjun Sheoran, Advocate
for Non-Applicants/Intervenors
[in CWP No.4507 & 4513 of 2020].
****
Dr. S. Muralidhar, J.
1. This is a batch of five petitions, by the companies belonging to the same
group. The first of these petitions i.e. CWP No.4144 of 2020 is filed by M/s
Ireo Hospitality Company Private Limited ('IHCPL') where the principal
challenge is to the provisional attachment order dated 7th February, 2020
issued by the Principal Commissioner, CGST Commissionerate, Gurugram
attaching the bank accounts of the Petitioner.
2. When CWP No.4144 of 2020 was listed for hearing before this Court on
14th February, 2020, notice of motion was issued and the petition was
adjourned to 18th February, 2020 at the request of learned standing counsel
for the Respondents.
3. On the following date i.e. 18th February, 2020 while further adjourning
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CWP No.4144 of 2020

the case to 25th February, 2020 again at the request of learned counsel for
the Respondents, the Court directed that in the meanwhile the Over Draft
(OD) account(s) of the Petitioner shall be de-freezed forthwith.
4. On the next date i.e. on 25th February, 2020 the following order was
passed in CWP No.4144 of 2020.
“By this petition, the petitioner has challenged the order

of attachment of its bank account under Section 83 of the
Central Goods and Services Tax Act, 2017 [read with
Rule 159 of the Central Goods and Services Tax (CGST)
Rules, 2017].
Reply on behalf of respondents has been
filed and the same is taken on record. Copy of reply is
handed over to learned counsel for the Petitioners.
The principal argument is that the necessary
concomitant for exercising the powers under Section 83
of the Act is 'opinion of the Commissioner that it is
necessary for protecting the interest of the Government
revenue'. On the other hand, the impugned order only
mentions that since proceedings have been launched
against the petitioner under Section 67 of the Act, the
order has been passed.
We have asked learned counsel for the
respondents as to what were the reasons for coming to
the opinion that the interest of the revenue may be
prejudicially affected when there is no demand,
because even in the written statement nothing is
forthcoming.
Learned counsel has requested us to permit
the officer who has passed the order to appear before this
Court with the record and explain the reasons which
weighed with him. Even though the request is hardly
reasonable, we accede to it.
Adjourned to 27.02.2020.
Copy of the order be handed over to learned
counsel for the Revenue under the signatures of Bench
Secretary of this Court.
Photocopy of this order be placed on the file
of each connected case.”
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CWP No.4144 of 2020

5. In the meanwhile, companion petitions had been filed and the above
order was common to the first petition i.e. CWP No.4144 of 2020 and the
other four petitions by the other group companies viz., Ireo Victory Valley
Private Limited (CWP No.4506 of 2020), Ireo Grace Realtech Private
Limited (CWP No.4507 of 2020), Ireo Residences Company Private
Limited (CWP No.4512 of 2020) and Ireo Private Limited (CWP No.4513
of 2020). The challenge in those petitions inter alia was to the attachment
of bank accounts of the concerned entities.
6. Thereafter, the petitions were again considered, after completion of the
pleadings, on 3rd March, 2020 when the following order was passed by this
Court:-
“Learned counsel for the Petitioners has filed

rejoinder to the reply of the respondents and the same is
taken on record. Copy of rejoinder is supplied to learned
counsel for the respondents.
Today, Mr. Vivek Ranjan, I.R.S., Director
General of GST Intelligence, Gurugram is present in the
Court and has apprised the Court that the order which has
been passed under Section 83 of the Central Goods and
Services Tax Act, 2017 read with rule 159(1) of the
Central Goods and Services Tax (CGST) Rules, 2017 and
in consonance with Form GST-DRC-22 and as per that
form, there is no requirement for recording the reasons.
In our opinion, this argument may not stand
the scrutiny of law because the enabling section is
section 83 which requires that 'Commissioner is of the
opinion that for the purpose of protecting interest of the
Government revenue.....'.
To our mind, tentatively the sine qua non for
the Commissioner to arrive at 'opinion' would be material
and and once Rule 159(5) permits the effected person
to file objections, it would normally go without saying
that he would know the reasons because if he does not
know the reasons, he does not what objections to file.
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CWP No.4144 of 2020

Adjourned to 17.03.2020 for further

consideration.
While recording our appreciation for
appearance of the Officer, we declare that he need not be
present on next date.
A photocopy of this order be placed on the
file of each connected case.
7. Further submissions were heard by this Court on 17th March, 2020 when
it was urged by Mr. Balbir Singh, learned Senior counsel for the Petitioner
that as long as the Petitioners' principal grievance that the provisional
attachment orders were non-reasoned orders is entertained and a time bound
direction is issued to the respondent to pass those orders afresh in
accordance with law taking into account the submissions of the Petitioners
in these petitions, the petitioners were willing to abide by any terms and
conditions as may be deemed appropriate by the Court.
8. Mr.Singh, inter-alia, stated on instructions that an affidavit would be
filed by the petitioners setting out what the balance in the frozen accounts
was, as on date, and also set out the proposed withdrawals to be made from
those accounts in the event of lifting of freezing orders by the Respondents
till 10th April, 2020, the tentative date by which it was proposed that fresh
orders would be passed by the Respondents.
9. Today, Mr. Balbir Singh, Senior Advocate has handed over an affidavit
dated 17th March, 2020 of the Petitioners setting out in a tabulated form the
payments that were required to be made by the Petitioners as “essential
business payments” upto 10th April, 2020 from the provisionally attached
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CWP No.4144 of 2020

accounts for running their day to day operations and for “no other purpose”.
The proposed payments have been depicted as under:-
S. No. Particulars Approximate Expense

a. Payment to Government and Local Rs.8.75 Crore
Authorities for statutory dues and
utility charges;
b. Payments to Banks and Financial Rs.9.25 Crore
Institutions against borrowings;
c. Payments on account of employee Rs.4.75 Crore
salary
d. Payments to existing vendors for Rs.4.75 Crore
completing live residential and
commercial projects
Total Rs.27.50 Crore
10. It is further stated in paragraph 4 of the affidavit that the Petitioner
companies expect further receipts of Rs.7 crores upto 10th April, 2020 on
account of customer payments. It is further urged by Mr. Balbir Singh that
money received by IHCPL by way of borrowings, loans, OD facility and
CC limit ought not to be attached by the Respondents and that the interim
order already passed in this regard by this Court on 18 th February, 2020
should be made absolute.
11. Mr. Balbir Singh, Senior Advocate has further highlighted what is
stated in paragraph 6 of the affidavit, that the Petitioners' have fixed
deposits (FD) in various bank accounts to the tune of Rs.52,23,71,188/-
which are under lien on account of security except FDR of Rs.1,43,31,817/-
which is free from encumbrances.
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CWP No.4144 of 2020

12. Mr. Sourabh Goel, learned senior panel counsel for Union of India
submitted that the affidavit was not explicit whether there was any other
account of the Petitioners and whether any sums have been received by the
Petitioners between 7th February, 2020 to till date.
13. Mr. Balbir Singh, Senior Advocate, further on instructions, undertakes
that subject to the impugned orders being set aside, the time bound
directions be issued to the respondents to pass fresh orders in accordance
with law, the Petitioners would ensure that no payments other than those set
out in the tabular form (in para 9 above) would be made from the accounts
till date of passing of fresh orders will remain untouched. He also states
that again on instructions, that the petitioner would furnish to the
respondents the receipts for the payments made to the vendors for
completing the live residential and commercial projects of the Petitioners,
accompanied by an affidavit explaining the details of such payment.
Thirdly, the Petitioners will maintain status quo with regard to FDs, both
which are under lien as well as the FDR which is free from incumbrances.
14. Mr. Balbir Singh, Senior Advocate, further on instructions, undertakes
that subject to the impugned orders being set aside, the time bound
directions be issued to the Respondents to pass fresh orders in accordance
with law, the Petitioners would ensure that no payments other than those set
out in the 'tabular form' would be made from the accounts and that further
receipts in the accounts till date of passing of fresh orders will remain
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CWP No.4144 of 2020

untouched. He also states, again on instructions, that the Petitioners would
furnish to the Respondents the receipts for the payments made to the
vendors for completing the live residential and commercial projects of the
Petitioners, accompanied by an affidavit explaining the details of such
payments. Thirdly, the Petitioners will maintain status quo with regard to
FDs, both which are under lien as well as the FDR which is free from
encumbrances.
15. Binding down the Petitioners to the aforementioned statement made
before the Court as recorded in paras 13 and 14 above, the following
directions are issued:-
(i) The impugned order of provisional attachment of
Petitioners' bank accounts are hereby set aside upon the
condition that fresh orders would be passed by the Respondent
No.2 in that regard, in accordance with law, taking into
account the submissions made by the Petitioners in these
petitions, not later than 10th April, 2020.
(ii) The said orders will be communicated to each of the
Petitioners not later than 12th April, 2020.
(iii) It will be open to the Petitioners, if aggrieved by such
orders, to seek appropriate remedies in accordance with law.
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CWP No.4144 of 2020

16. It is made clear that the Court has not expressed any opinion on the
contentions of the Petitioners or of the response of the Respondents thereto.
These are left open to be urged by the parties at the appropriate stage.
17. It is clarified that the interim order already passed by this Court on 18 th
February, 2020, viz., de-freezing the OD account of IHCPL, including any
borrowings, terms loans, CC limits will continue.
18. The petitions are disposed of in the above terms.
19. Order dasti.
[S. MURALIDHAR]
JUDGE
[AVNEESH JHINGAN]
JUDGE
March 18, 2020
pankaj baweja
1. Whether speaking/ reasoned : Yes
2. Whether reportable : Yes
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ANNEXURE A-8
$~48, 50, 51, 53, 54 & 55

* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ W.P.(C) 7444/2019
RAMESH SANKA ..... Petitioner
Through: Mr Ankit Jain, Advocate.
versus
OF INDIA AND ANR. ..... Respondents
Through
WITH
50.
+ W.P.(C) 7461/2019
versus
Through
WITH
51.
+ W.P.(C) 7463/2019
versus
OF INDIA THROUGH ITS CHAIRMAN & ANR ..... Respondents
Through
WITH
53.
+ W.P.(C) 7477/2019
Through: Mr Ankit Jain, Advocate
&
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471
versus
Through
WITH
54.
+ W.P.(C) 7485/2019
versus
Through
AND
55.
+ W.P.(C) 7488/2019
versus
INSTITUTE OF CHARTERED ACCOUNTANT
OF INDIA THROUGH ITS CHAIRMAN & ANR ..... Respondents
Through
CORAM:
HON'BLE MR. JUSTICE VIBHU BAKHRU
ORDER
% 15.07.2019
CM No.31075/2019 in W.P.(C) 7461/2019
CM No.31078/2019 in W.P.(C) 7463/2019
CM No.31098/2019 in W.P.(C) 7477/2019
CM No.31108/2019 in W.P.(C) 7485/2019
CM No.31111/2019 in W.P.(C) 7488/2019
1. Allowed, subject to all just exceptions.

W.P.(C) 7444/2019 & CM No.31010-31011/2019
&
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472
W.P.(C) 7461/2019 & CM No.31074/2019

W.P.(C) 7463/2019 & CM No.31077/2019
W.P.(C) 7477/2019 & CM No.31097/2019
W.P.(C) 7485/2019 & CM No.31107/2019
W.P.(C) 7488/2019 & CM No.31110/2019
2. The petitioner has filed the present petitions, inter alia, being
aggrieved by the inaction on part of respondent no.1 (Institute of Chartered
Accountants of India-ICAI) in considering the complaints filed by the
petitioner.
3. The petitioners claim that it had made six separate complaints of
misconduct against separate persons, who are arrayed as respondent no.2 in
these petitions, to ICAI. Such complaints were in respect of their conduct in
relation to Ireo Group Companies.
4. The learned counsel appearing for the petitioner submits that the
petitioner would be satisfied if directions are issued to ICAI for examining
the petitioner’s complaints in a time bound manner.
5. Given the limited relief sought for by the petitioners, this Court does
not consider it necessary to issue notice to the respondents.
6. In terms of Sub-section (2) of Section 21 of the Chartered Accounts
Act. 1949, the Director (Discipline), ICAI is required to form a, prima facie,
opinion regarding the occurrence of alleged misconduct. In terms of sub-
section (3) of Section 21 of the said Act, where the Director (Discipline) is
of the opinion that the member is guilty of any professional misconduct as
mentioned in First Schedule, he is required to place the same before the
Board of Discipline. In cases where Director (Discipline) is of the opinion
that the member is guilty of any professional misconduct as mentioned in
the Second Schedule or both the Schedules, he is required to place the same
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473
before the Disciplinary Committee.

7. The petitioner states that in the present case, the Director (Discipline)
has, as yet, not taken any view as to the occurrence of the misconduct as
alleged.
8. In the circumstances, this Court directs the Director (Discipline),
ICAI to take a view as required under sub-section (2) of Section 21 of the
Act as expeditiously as possible, and preferably within a period of three
months, from today.
9. The petition is disposed of with the aforesaid directions. The pending
applications are also disposed of.
10. It is clarified that this Court has not expressed any opinion (prima
facie or otherwise) on the merits of the complaints or whether the acts
complained of constitute misconduct or other misconduct as specified in the
Schedules to the Chartered Accounts Act, 1949. And, nothing stated in this
order should be construed as an expression of any such opinion.
VIBHU BAKHRU, J
JULY 15, 2019
MK
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C.M. NO.____________OF 2023
IN
W.P. (C) NO. ________/2023
IN THE MATTER OF:

VERSUS

APPLICATION UNDER SECTION 151 CPC, 1908 SEEKING

EXEMPTION FROM FILING CERTIFIED COPIES AND
FURTHER SEEKING DIRECTIONS FROM FILING TRUE
TYPED/LEGIBLE COPIES OF DIM DOCUMENTS,
UNDERLINED DOCUMENTS, DOCUMENTS NOT HAVING
REQUSITE FONT SIZE AND MARGINS
MOST RESPECTFULLY SHOWETH:
1. Petitioner is constrained to file the present Petition against
action/inaction by Respondent No. 1/ Institute of Chartered
Accountants of India (ICAI) for having neglected in performing
its duty and failure issue to issue a prima facie opinion as per
Section 21 of Chartered Accountant Act, 1949 on the basis of
Complaint dated 28.02.2020 filed by Petitioner No.1 reporting the
issue of professional misconduct of Respondent No. 2/ Mr. Vinesh
Jain (Partner at S.N. Dhawan & Co.)

625
2. Along with the Petition, Petitioner has also filed certain
documents in support of the Petition. Petitioner at present does not
have legible/original/typed/margin copies of some of the
documents. In view of the urgency, the Petition is being filed
without awaiting the legible/original/certified/typed/margin
copies. The Petitioner shall file the same as and when directed by
this Hon’ble Court.
3. In view of the above and on account of the exigency in the matter,
the Petitioner is praying for an exemption from filing certified
copies, better legible copies of dim documents, original/ typed/
margin copies of the documents in the accompanying Petition.
4. This application is bonafide and in the interest of justice.
PRAYER
It is therefore most respectfully prayed that this Hon’ble Court may be
pleased to:
(a) Exempt the Petitioner from filing the original/certified copies of
documents, legible/typed copies of dim/ underlined documents
and documents not having requisite font size or margins, in the
accompanying Petition; and

626
627
628
Telangana 03
NCT OF DELHI COURT_FEE
DLCT05222511<221 BL
05-NOV-2022
NCTOF DELHI COURT FEE
DLCT2415443K2140L
24-NOV-2021
629
11111mHlllll!IIHIIIIII IW111111111111111m111111m11111111m I
W.P. (C) NO. --~/2023
IN THE MATTER OF:
RAMESH SANK.A ... PETITIONER
VERSUS

OF INDIA & ANR. . .. RESPONDENT(S)
VAKALA TNA1\1A
KNOW ALL to whom these presents shall come that I, Mr. Ramesh Sanka, S/o Mr.
Eswarudu Sanka, aged about 62 years, Rio 1611-B, Magnolias, DLF-5, Gurgaon,
Haryana-122009, presently at Hyderabad, the Petitioner in the captioned Petition,
do hereby appoint:
Zeba Khair / Nimita Kaul/ Shivambika Sinha/ Nikita Jain/ Ananya Garg
[D/793-/1998] / [D/4480/2010] / [D/2555/2010]/ [D/10691/2021]/ [D/5956/2022]
Advocates for Petitioner, having office at: 27, Pocket 1, JasolaVihar Delhi - 11 0025, M.
No. +91-98106 02612 [hereinafter called the advocate(s)], to be my/our Advocate(s) in the
above noted case authorized them:
To act, appear and plead in the above-noted case in this Court or in any other Court in
which the same may be tried or heard and also in the Appe1late Court including High Court _
subject to payment of fees separately for each Court by me.
To sign, file, verify and present pleadings, appeals, cross objections or petitions for
execution review, revision, withdrawal, compromise or other petitions or affidavits or
other documents as may be deemed necessary or proper for the prosecution of the said case
in all its stages.
To file and take back documents and to admit and/or deny the documents of opposite party.
And I the undersigned do hereby agree to ratify and confirm all acts done by the
Advocate(s) or his substitute in the matter as my/our own acts, as if done by me/us to aU
intents and purposes.
And I undertake that I or my duly authorized agent would appear in the Court on all
hearings and will inform the Advocate(s) for appearance when the case is called.
And I the undersigned do hereby agree not to hold the Advocate(s) or his substitute
responsible for the result of the said case.
The fee settled is only for the above case and above Court.
IN WITNESS WHEREOF I do hereunto set my hand to these presents the content~___.Qf

JAN
which have been understood by me on this _03
_day of _ _ _ _ _ 2023. / / /
Accepted subject to the terms of fees. / -j:L/
Adv~e Client ;7 ,
1/23/23, 11:37 AM Gmail - Service: Fresh Writ Petition Civil titled Ramesh Sanka Vs. Institute of Chartered Accountants of India & Anr.
630
Satish Kumar <satishkumar8673@gmail.com>
Service: Fresh Writ Petition Civil titled Ramesh Sanka Vs. Institute of Chartered
Accountants of India & Anr.
1 message
Satish Kumar <satishkumar8673@gmail.com> Mon, Jan 23, 2023 at 11:37 AM

To: president@icai.in, vinesh.jain@sndhawan.com
Respected Sir,
Kindly accept the service of the fresh Writ Petition Civil titled Ramesh Sanka Vs. Institute of Chartered Accountants of
India & Anr.
For Respondent No. 1

Email: president@icai.in
For Respondet No. 2

Email: vinesh.jain@sndhawan.com
Regards
Satish Kumar (Clerk)
for
Zeba Khair (Advocate)
Email:
M. No.
9810602612
ICAI Writ DHC compressed.pdf
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TO l3E FlLLED BY HAND Pagel

• IN THE HIGH COURT OF DELHI AT NEW DELHI

le} ,~, ICI I I I I I I ioF klol~u,

I (a) Case Category I I I I 1· [D

4 Statute Involved iPlelTll frl 11 °1NI IUI/ ~I 12.l?J6l 1°1FI ITll-\161 I

Motors Accident Claim Matters -

81 r,,60 ~-6 / '2-

IN THE MATTER OF:

INSTITUTE OF CHARTERED ACCOUNTANTS

SR. NO. PARTICULARS PAGE NO.

4. Memo· of parties 4-5

5. Synopsis & list of dates 6-12

6. Writ petition under article 226 and 227 of the 13-41

21. Proof Of Services 630

Zeba Khair/Shivambika Sinha/Nimita Kaul

IN THE HIGH COURT OF DELHI AT NEW DELHI

IN THE MATTER OF:

INSTITUTE OF CHARTERED ACCOUNTANTS

Zeba Khair/Shivambika Sinha/Nimita Kaul

IN THE HIGH COURT OF DELHI AT NEW DELHI

IN THE MATTER OF:

INSTITUTE OF CHARTERED ACCOUNTANTS

Zeba Khair/Shivambika Sinha/Nimita Kaul

IN THE HIGH COURT OF DELHI AT NEW DELHI

IN THE MATTER OF:

INSTITUTE OF CHARTERED ACCOUNTANTS

Zeba Khair/Shivambika Sinha/Nimita Kaul

IN THE HIGH COURT OF DELHI AT NEW DELHI

W.P. (C) NO. ________/2023

IN THE MATTER OF:

INSTITUTE OF CHARTERED ACCOUNTANTS

INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA

Zeba Khair/Shivambika Sinha/Nimita Kaul

IN THE HIGH COURT OF DELHI AT NEW DELHI

IN THE MATTER OF:

INSTITUTE OF CHARTERED ACCOUNTANTS

SYNOPIS AND LIST OF DATES

Petitioner is constrained to file the present Petition

against action/inaction by Respondent No. 1/ Institute of Chartered

Accountants of India, 1949 (ICAI ) for having neglected in

facie opinion as per provisions of Section 21 of ICAI Act upon

receiving Complaint dated 28.02.2020 filed by Petitioner, reporting

the issue of professional misconduct by Respondent No. 2/ Mr.

Vinesh Jain (Partner at S.N. Dhawan & Co.) in his capacity as

statutory Auditor for Ireo Pvt. Ltd. Respondent No. 2 is a Chartered

Accountant by profession, and has been actively involved in scam/

embezzlement of funds and tax evasion to the tune of INR 727

crores and more and hence is guilty of breach of his professional

(Fund manager& VC & MD of Ireo Pvt. Ltd.) and other key

management personnel of Ireo Pvt. Ltd. in carrying out the massive

duties. It is submitted that Respondent No. 2 gave wrong disclosures,

non-disclosures and manipulated the books of accounts of Ireo Pvt. Ltd.

leading to concealment of vital information from the tax authorities,

investors and more essentially from the Government of India in order to

evade tax and siphon money illegally.

Petitioner had been appointed at the post of Chief Executive Officer

financial embezzlements going on in the Company, Petitioner shortly

resigned from his position with effect from 31.12.2016.